2018 was an interesting year for those of us in the compliance field. We completed implementation of HMDA and TRID revisions, and got a jump start on implementing the provisions of the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA). In last year’s New Years greeting I stated, “In my 42-year career I have seen the pendulum swing from one extreme to another several times. Since the mortgage crisis 10 years ago we have […]
Category: HMDA
Final 2019 Lending Thresholds Released
On December 31, 2018, with the last few hours of 2018 quickly approaching, the Consumer Financial Protection Bureau has published the final lending threshold updates just in time for 2019. The updates include: The HMDA asset-size exemption threshold, increased from $45 million to $46 million. The final rule is available here. The Truth in Lending asset-size exemption for certain creditors to qualify for an exemption to the requirement to establish an escrow account for a […]
BUREAU RELEASES UPDATED HMDA FIG FOR 2019
The Bureau of Consumer Financial Protection has released the Filing Instructions Guide, or FIG, for Home Mortgage Disclosure Act (HMDA) data collected in 2019 and reported in 2020. There are no significant changes to the submission process for data collected in 2019 and reported in 2020 and, therefore, no significant changes to the FIG. However, updates were made and financial institutions will need to be aware of the changes to the FIG for data collected in 2019. A […]
HMDA FINAL RULE FOR EGRRCPA EXEMPTION
On August 31 the Bureau of Consumer Financial Protection issued a final rule to implement and clarify the requirements of section 104(a) of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA), which amended certain provisions of the Home Mortgage Disclosure Act (HMDA). The rule clarifies: That insured depository institutions and insured credit unions covered by a partial exemption under the EGRRCPA have the option of reporting exempt data fields as long as they report […]
STATUS OF THE EGRRCPA HMDA AMENDMENTS
On July 5, 2018 both the Office of the Comptroller of the Currency (OCC Bulletin 2018-19) and the Consumer Financial Protection Bureau issued statements regarding the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) amendments to the Home Mortgage Disclosure Act (HMDA). The President signed the EGRRCPA on May 24, 2018. Section 104 of the law amends HMDA. The EGRRCPA provides exemptions from certain HMDA requirements for insured depository institutions, with satisfactory or outstanding […]