The FDIC reminded FDIC-supervised institutions subject to the Home Mortgage Disclosure Act ("HMDA") of a recently Consumer Financial Protection Bureau ("CFPB") interpretive and procedural rule that implements and clarifies Home Mortgage Disclosure Act ("HMDA") amendments made by the Economic Growth, Regulatory Relief and Consumer Protection Act.
The HMDA amendments provide partial exemptions to certain insured depository institutions and insured credit unions (collectively, "eligible IDIs") from reporting requirements related to closed-end mortgage loans and open-end lines of credit. The partial exemptions are available to eligible IDIs that meet conditions related to mortgage origination thresholds and Community Reinvestment Act performance ratings.
The CFPB's rule - which went into effect on September 7, 2018 - clarifies which data points are covered by the partial exemptions, and confirms that only loans and lines of credit otherwise reportable under Regulation C count toward the origination thresholds. The rule also clarifies that eligible IDIs can (i) use a non-universal loan identifier for partially exempt transactions and (ii) choose to report exempt data points if they report all data fields included in that particular data point.
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