CFPB Announces Annual Adjustments to HMDA Asset-Size Exemption Thresholds and Launch of New HMDA Online Tools

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The CFPB has recently issued several announcements impacting financial institutions that submit data under the Home Mortgage Disclosure Act (HMDA). First, the CFPB has increased the asset-size exemption threshold under HMDA and Regulation C to $45 million from the current $44 million threshold.  Accordingly, banks, savings associations, and credit unions with assets totaling $45 million or less as of December 31, 2017, are exempt from collecting HMDA data in 2018.

Second, the CFPB has released an updated rate spread calculator and check digit tool.  The rate spread calculator provides rate spreads for HMDA reportable loans with a final action date on or after January 1, 2018.  The rate spread calculator generates the spread between the Annual Percentage Rate (APR) and a survey-based estimate of APRs currently offered on prime mortgage loans of a comparable type utilizing the “Average Prime Offer Rates” fixed table or adjustable table, action taken, amortization type, lock-in date, APR, fixed term (loan maturity) or variable term (initial fixed-rate period), and reverse mortgage. Note that the prior rate spread calculator must continue to be used for loans with a final action date before January 1, 2018.

In addition, the check digit tool can be used for two functions: (1) to generate a two character check digit when an entity enters a Legal Entity Identifier (LEI) and loan or application identification (ID); and (2) to validate that a check digit is calculated correctly for any complete Universal Loan Identifier (ULI).

Third, as of January 1, 2018, the HMDA Platform is available to submit HMDA data collected in 2017.  Financial institutions can use the online HMDA Platform to upload their loan/application registers (LARs), review edits, certify the accuracy and completeness of the data, and submit data for the filing year.  Each user will need to register online for login credentials and establish an account in order to access the platform.

The CFPB’s announcement regarding the HMDA asset-size exemption threshold can be found at: https://www.gpo.gov/fdsys/pkg/FR-2017-12-27/pdf/2017-27879.pdf.

The HMDA resource tools can be found at: https://www.consumerfinance.gov/data-research/hmda/for-filers.

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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