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 […]
Tag: Regulation C
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. […]