HMDA Exemption for Large CRA Reporters
Adam uses this Compliance Clip (video) to talk about one of the nuances of the CFPB’s Interpretive and Procedural Rule regarding the HMDA partial exemption. Specifically, this video explains how the property address and property location data points apply to large CRA reporters who also qualify for the HMDA partial exemption. The answer might not be exactly what you think…. or even what the CFPB intended.