HMDA thresholds continued: The partial exemption
Recently we blogged about the Home Mortgage Disclosure Act (HDMA) and the reporting thresholds found in Regulation C. Today, we’ll focus on another set of thresholds in Regulation C – those which determine whether a credit union qualifies for the “partial exemption.”
First, let’s quickly review what was covered in that previous blog: Regulation C sets out activity thresholds which determine if a credit union is required to collect, record, and report certain data under HMDA. These thresholds look back at the credit union’s number of originations in each of the preceding two years – so when determining whether a credit union is required to collect HMDA data for applications received in 2022, the credit union will look at the number of originations in 2020 and 2021. For 2022, the thresholds are currently set at 100 originations for closed-end mortgages and 200 originations for home-secured open-end credit.
So where does the “partial exemption” come in? If a credit union determines that it is required to collect, record, and report HMDA data, then the partial exemption determines which HMDA datapoints it must collect, record and report.
Under section 1003.3(d) of Regulation C, an insured credit union can qualify for the partial exemption if it originated fewer than 500 closed-end mortgages or 500 home-secured open end lines of credit in each of the preceding two calendar years. As you can see, these thresholds work similarly to the activity thresholds mentioned above – they look at originations made in each of the previous two years, and they also operate independently (meaning that a credit union could receive the exemption for just closed-end credit, just open-end credit, or for both).
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