Blog — Compliance Cohort

On June 13, 2022, the CFPB published the Beginner’s Guide to Accessing and Using Home Mortgage Disclosure Act Data. The guide will serve as a resource to support a range of stakeholders in accessing and using HMDA data, the largest source of publicly available data on mortgage lending in the United States.

Apr 15

Apr 15 VIDEO: HMDA Demographic Information Determinants

In this Compliance Clip, Adam answers a question which had been a topic of debate before the CFPB finally issued a guidance, that is whether to list code 2 or code 3 on the HMDA LAR for when information about determinants are not available. And if you don’t know what is a determinant, watch this video to find out. A transcript of this video is now available.

Apr 5
Apr 5 Revised HMDA Getting It Right Guide for 2022

On 3/29/2022, the FDIC announced that the Federal Financial Institutions Examination Council (FFIEC) had issued the 2022 edition of A Guide to HMDA Reporting: Getting It Right! for Home Mortgage Disclosure Act (HMDA)-related data collected in 2022 and reported in 2023. This longstanding compliance resource has regularly been used by financial institutions as a “go-to” HMDA resource as it can help financial institutions better understand HMDA requirements, including the data collection and reporting provisions.

Mar 25

Mar 25 VIDEO: HMDA Income & Property Value in Credit Decisions

In this Compliance Clip, Adam answers a HMDA question on whether income and property value should be included in the HMDA LAR when they are not the deciding factor, but are used in determining a credit decision. In other words, when income and property value were factors in the credit decision, but they're just a partial factor, should they be reported?

Mar 4

Mar 4 VIDEO: HMDA Temporary Construction Loan Modification

In this Compliance Clip (video), Adam answers a question that he recently received about reporting a temporary construction loan that has been modified on the HMDA LAR. Specifically, the initial loan was temporary financing and was designed to be replaced by a permanent loan, but was not sold on the Secondary Market as intended. Watch as Adam tries to simplify a somewhat confusing topic. A transcript of this video is now available.

Feb 7
Feb 7 CFPB Issues 2022 Reportable HMDA Data Reference Chart

On 1/27/22, the CFPB issued Version 1 of the 2022 Reportable HMDA Data: A Regulatory and Reporting Overview Reference Chart. The 38-page chart is intended to be used as a reference tool for data points required to be collected, recorded, and reported under Regulation C.

Dec 27
Dec 27 2022 HMDA Exemption Threshold

On December 23, 2021, the CFPB adjusted the HMDA exemption threshold from $48 million to $50 million. The adjustment is based on the 4.7 percent increase in the average of the CPI-W for the 12-month period ending in November 2021 (up from 1.6 in 2019 and 1.3 in 2020). Therefore, banks, savings associations, and credit unions with assets of $50 million or less as of Dec. 31, 2021, are exempt from collecting data in 2022.

Dec 20
Dec 20 Revised HMDA Interagency Examination Procedures

HMDA, Regulatory Update

On 12/17/21, the OCC issued the revised interagency Home Mortgage Disclosure Act (HMDA) examination procedures for determining compliance with HMDA and its implementing regulations. The interagency procedures update the April 19, 2019, FFIEC interagency examination procedures for the Home Mortgage Disclosure Act.

Nov 18
Nov 18 APOR Rates Delayed for Week Of 11/15/21