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 […]
Tag: HMDA
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 […]
HMDA GETTING IT RIGHT IS BACK
The Federal Financial Institutions Examination Council (FFIEC) has released an updated and expanded version of the publication A Guide to HMDA Reporting – Getting it Right (aka the HMDA bible). The publication had not been updated since 2013. The 327-page 2018 Guide is updated for the revisions to the Consumer Financial Protection Bureau’s (CFPB) Regulation C, which implements the Home Mortgage Disclosure Act (HMDA) that were effective January 1, 2018. The Guide includes the revised […]
OTTING MISSTATEMENT
Last week Comptroller of the Currency Joseph M. Otting issued a statement after meeting with Mick Mulvaney, Acting Director of the Consumer Financial Protection Bureau. According to the news release (NR 2018-14) from the Office of the Comptroller of the Currency (OCC) Comptroller Otting stated “Acting Director Mulvaney has helped reduce the burden on the banking system by delaying implementation of his agency’s Home Mortgage Disclosure Act rule, committing to reconsider its payday lending rule, and […]