Revised HMDA Examination Guidelines Issued

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The CFPB recently posted on its website revised Home Mortgage Disclosure Act (HMDA) examination guidelines.

The revised guidelines address the exemption adopted in the Economic Growth, Regulatory Relief, and Consumer Protection Act (also known as S.2155) applicable to the new HMDA data categories added by Dodd-Frank and the HMDA rule adopted by the CFPB in October 2015. The exemption is available for insured depository institutions and insured credit unions that originate mortgage loans below certain thresholds and meet certain Community Reinvestment Act rating criteria. We previously reported on the exemption and a related interpretive rule issued by the CFPB in September 2018.

The Office of the Comptroller of the Currency also issued Bulletin 2019-19 that addresses the revised examination guidelines.

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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