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 by the Federal Reserve Board’s Regulation C. But last July Regulation C was transferred from the Federal Reserve to the CFPB.

For many years the Fed has published the new asset threshold each year during the second or third week of December. But apparently the CFPB was asleep at the wheel in December 2011. They were two months late publishing the new threshold.

Granted this minor delay only impacts a few financial institutions, but from my perspective it appears that the CFPB owes us all two months. If we are little late with a deadline they should cut us some slack, up to two months worth, in any event. Yeah sure. Well it’s nice to dream, isn’t it?

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