CFPB updates HMDA Small Entity Compliance Guide

Happy Hump Day and Happy Puzzle Day!

Let’s celebrate by piecing together the partial exemptions of HMDA, using some updated guidance to help.

Last week, the CFPB released an updated version of its Home Mortgage Disclosure Act (HMDA) Small Entity Compliance Guide. The new version reflects changes made by the Bureau’s rule in October to extend by two years the temporary threshold of 500 for reporting open-end lines of credit. This means credit unions that have not originated at least 500 open-end lines of credit in each of the two preceding years are excluded from certain reporting requirements until the year 2022. If this is your first time hearing about the updates to HMDA, check out my previous blog on the amendments.

Beside incorporating the new thresholds for reporting, the rule and the updated guide clarified the partial exemptions from certain HMDA requirements under the Economic Growth, Regulatory Relief, and Consumer Protection Act. These partial exemptions will become effective in 2022 after the expiration of the complete exemption for loans made beneath the reporting threshold amounts. For a credit union to use a partial exemption, it must be an “insured credit union” as defined in Section 101 of the Federal Credit Union Act, as well as originate loans that fall below the thresholds of 25 loans or 500 lines of credit.


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