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 Community Reinvestment Act ratings, and for insured credit unions. The partial exemptions are generally available:

  • For closed-end mortgage loans if the institution originated fewer than 500 closed-end mortgage loans in each of the two preceding calendar years.
  • For open-end lines of credit if the institution originated fewer than 500 open-end lines of credit in each of the two preceding calendar years.

The partial exemption eliminates the requirement to collect, record, and report some, but not all, of the data points specified in current Regulation C. The data points from Sections 304(b)(5) and (6) are eliminated for this select group of financial institutions.

For all institutions filing HMDA data collected in 2018, the Act will not affect the format of the LARs:

  • LARs will be formatted according to the previously-released 2018 Filing Instructions Guide for HMDA Data Collected in 2018 (2018 FIG).
  • If an institution does not report information for a certain data field due to the Act’s partial exemptions, the institution will enter an exemption code for the field specified in a revised 2018 FIG.
  • All LARs will be submitted to the same HMDA Platform. A beta version of the HMDA Platform for submission of data collected in 2018 will be available later this year for filers to test.

At some unspecified date, later this summer, the  CFPB expects to release the revised 2018 FIG and to provide further guidance on the applicability of the Act to HMDA data collected in 2018.

For more about the EGRRCPA read: https://www.jackscomplianceresource.com/regulatory-relief-on-the-way/; or purchase a two-hour webinar on the topic at:  https://www.jackscomplianceresource.com/product/the-economic-growth-regulatory-relief-and-consumer-protection-act-immediate-compliance-concerns-webinar-recording/

The OCC Bulletin is available at: https://www.occ.gov/news-issuances/bulletins/2018/bulletin-2018-19.html

The CFPB statement is available at:  https://www.consumerfinance.gov/about-us/newsroom/bureau-consumer-financial-protection-issues-statement-implementation-economic-growth-regulatory-relief-and-consumer-protection-act-amendments-home-mortgage-disclosure-act/

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