All in HMDA

OCC Releases List of Key HMDA Data Points

Adam Witmer
Regulatory Update, HMDA

On March 7, 2019, the Office of the Comptroller of the Currency (OCC) released a bulletin (2019-12) explaining the key HMDA data fields for full and partial HMDA reporters.  In their bulletin, the OCC explains that key data fields have been identified to support the efficient and effective evaluation of banks’ compliance with HMDA requirements. Of the 110 total data fields, 37 have been identified as key fields by the OCC, Federal Reserve Board (FRB), and Federal Deposit Insurance Corporation (FDIC) on an interagency basis. The OCC explains that OCC examiners will typically test and validate these 37 key fields for the banks that are required to collect, record, and report information for all HMDA data fields. For banks that qualify for a partial exemption from the HMDA data collection, recording, and reporting requirements, OCC examiners will typically test and validate 21 of those 37 fields.

A Spec Home is Probably NOT HMDA Reportable - Here's Why

Adam Witmer
HMDA

While the revised HMDA rules have been in place for just over a year now, we are finding that a number of financial institutions are still struggling with a few of the quirks of the new rules.  Specifically, one question we have seen a few times in recent months is this: Is a spec home HMDA reportable? To fully understand the answer to this question, we need to first discuss how the changes to the 2018 HMDA rules relate to this topic.  You see, under the old HMDA rules, spec homes were…

HMDA Exemption Property Address

HMDA Exemption Property Address

Adam Witmer
HMDA

In this Compliance Clip (video), Adam discusses how the Property Address data point applies to the partial exemption. Specifically, he provides guidance on how exempt institutions are to report the street, city and state when they are listing the state data field as part of the Property Location data point. As you would expect, this is a fairly complex topic that has caused quite a bit of confusion, so Adam attempts to break the rules down into easy-to-understand layman’s terms.

If you are an exempt reporter or plan to use the partial exemption for your 2019 data, be sure to check out our Compliance Class (video webinar) on the HMDA partial exemption in our store. Everything you need to know about the partial exemption is covered in less than an hour and includes a comprehensive training manual for reference and a Q&A of some more complex questions relating to the partial exemption. View the Compliance Class (video webinar) at www.compliancecohort.com/hmda-webinar.

HMDA Exemption for Large CRA Reporters

HMDA Exemption for Large CRA Reporters

Adam Witmer
HMDA

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.

2019 HMDA Exemption Threshold

Adam Witmer
HMDA, Regulatory Update

On December 31, 2018, the CFPB adjusted the HMDA exemption threshold from $45 million to $46 million.  The adjustment is based on the 2.6 percent increase in the average of the CPI-W for the 12-month period ending in November 2018. Therefore, banks, savings associations, and credit unions with assets of $46 million or less as of Dec. 31, 2018, are exempt from collecting data in 2019.

State Field for HMDA Partial Exemption

Adam Witmer
HMDA

One might think that using the HMDA partial exemption for small filers would make life easier.  Much easier. Well, for the most part, that is true. The CFPB’s interpretive and procedural rule provides relief for certain “small HMDA filer” so that they are exempt from reporting about half of the data fields (22 out of 48 total data fields).  The problem with the HMDA partial exemption, however, is that the rules to comply with the partial exemption are actually quite confusing. For example, the CFPB interpretive and procedural rule provides a number of different ways to report exempt data fields, and even creates some confusion on one particular data field: the State data field.

HMDA Loan Amount For Counteroffers

Adam Witmer
HMDA

The new HMDA rules have created a whirlwind of challenges for HMDA reporters as reporters have had to learn which knowledge they could retain from the prior rules and which knowledge they had to adjust - not to mention the new elements that had to be learned.  The reality is that it takes time to get all of the “kinks out” when learning a new, especially one that is as complicated as HMDA and Regulation C. A prime example of the challenges that are created due to the implementation of a new rule is the HMDA loan amount when there has been a counteroffer.

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