BCFP Issues Update to HMDA Small Entity Compliance Guide

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The BCFP has issued an updated version of the HMDA Small Entity Compliance Guide to reflect the partial exemptions to some of the HMDA Rule’s requirements made by the 2018 Economic Growth, Regulatory Relief, and Consumer Protection Act and the 2018 HMDA Rule.

In general, the partial exemption provides eligible insured depository institutions and insured credit unions an exemption from the new HMDA data reporting categories added by the Dodd-Frank Act and the HMDA Rule adopted by the BCFP. With respect to closed-end mortgage loans, the partial exemption will apply if the institution or credit union originated fewer than 500 such loans in each of the preceding two calendar years. For home equity lines of credit (HELOCs), the partial exemption will apply if the institution or credit union originated fewer than 500 HELOCs in each of the preceding two calendar years.

The partial exemptions were effective May 24, 2018, and apply to the collection, recording, and reporting of HDMA data on or after that date.

The revised HMDA Small Entity Compliance Guide is available here.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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