On December 28th the Consumer Financial Protection Bureau (CFPB) issued a final rule adjusting the asset-size exemption threshold for banks, savings associations, and credit unions under Regulation C, which implements the Home Mortgage Disclosure Act (HMDA). The revised asset-size exemption for banks, savings associations, and credit unions has increased to $42 million. As a result, institutions with assets of $42 million or less as of December 31, 2012, are exempt from collecting HMDA data in […]
Category: HMDA
2011 HMDA DATA
HMDA data for 2011 was recently made available. The data include disclosure statements for each financial institution, aggregate data for each metropolitan statistical area (MSA), nationwide summary statistics regarding lending patterns, and Loan/Application Registers (LARs) for each financial institution (LARs are modified to protect borrower privacy). For 2011: The number of reporting institutions of 7,632 fell nearly 4 percent from the number in 2010, continuing a downward trend since 2006, when HMDA coverage included […]
STATUS OF OTHER PENDING RULES
We received a lot of positive feedback about yesterday’s blog entry on the status of changes to Regulation Z. Several of you inquired about the status of other pending rules, particularly those involving Regulations B and C. Well here you go… Regulation B – The Dodd-Frank Act amended the Equal Credit Opportunity Act (ECOA) to require financial institutions to report information concerning credit applications made by women- or minority-owned businesses and small businesses. The amendments […]
HMDA THRESHOLD – BETTER LATE THAN NEVER
Today the Consumer Financial Protection Bureau (CFPB) published the HMDA asset threshold. The exemption threshold has been adjusted to $41 million from $40 million. The adjustment is based on the 3.43 percent increase in the average of the CPI-W for the twelve-month period ending in November 2011. Therefore, depository institutions with assets of $41 million or less as of December 31, 2011 are exempt from collecting HMDA data in 2012. Remember, HMDA was previously implemented […]
HMDA – REPORTING PURCHASED/REPURCHASED LOANS
With continued problems in the mortgage markets, some HMDA-reporting institutions may be required to repurchase loans from an investor because of defaults or may have the opportunity to acquire loans in bulk from another institution. When a loan is repurchased by the originator within the same calendar year as originated, the originator should not report it as sold, and the purchaser (that subsequently puts it back to the originator) should not report it as purchased. […]