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FDIC Issues Statement on Implementing S. 2155’s HMDA Reporting Exemptions

July 06, 2018 / Source: FDIC

Financial Institution Letters

FIL-36-2018
July 5, 2018

Home Mortgage Disclosure Act:
Statement on the Implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act Amendments
Printable Format: 
FIL-36-2018 - PDF (PDF Help)

Summary:

The FDIC is releasing a statement on implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act (the Act) amendments to the Home Mortgage Disclosure Act (HMDA). The statement provides information on forthcoming guidance from the Bureau of Consumer Financial Protection on applicability of the Act to HMDA data collected in 2018, in addition to information on formatting and submission of HMDA data. The agencies are retaining their diagnostic examination approach regarding HMDA data collected in 2018 and reported in 2019.

Statement of Applicability to Institutions with Total Assets under $1 Billion: This Financial Institution Letter applies to all FDIC-supervised institutions subject to HMDA and Regulation C. A HMDA exemption applies to institutions with assets at or below a threshold specified in Regulation C.

Highlights:

HMDA, which is implemented by Regulation C, requires certain financial institutions to collect, report, and disclose information about their mortgage lending activity.

  • The Economic Growth, Regulatory Relief, and Consumer Protection Act (the Act), enacted on May 24, 2018, provides partial exemptions for some insured depository institutions from reporting certain HMDA data points. The partial exemptions are generally available to insured depository institutions and insured credit unions as follows:
    • For closed-end mortgage loans, if the institution originated fewer than 500 closed-end mortgage loans in each of the two preceding calendar years.
    • For open-end lines of credit, if the institution originated fewer than 500 open-end lines of credit in each of the two preceding calendar years.
  • For institutions filing HMDA data collected in 2018, the Act will not affect the format of the Loan/Application Registers (LAR). An exemption code will be provided for data fields to which a partial exemption applies. The 2018 formatting tool is available at https://ffiec.cfpb.gov.
  • On December 21, 2017, the FDIC issued a Statement on Financial Institutions' Good Faith HMDA Compliance Efforts (FIL-63-2017).

Distribution:

FDIC-Supervised Institutions

Suggested Routing:

Chief Executive Officer
Compliance Officer
Chief Lending Officer

Related Topics:

FIL-10-2018, FFIEC Revised A Guide to HMDA Reporting: Getting It Right!
FIL-63-2017, Home Mortgage Disclosure Act: Statement on Institutions' Good Faith Compliance Efforts

Attachment:

Statement on the Implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act Amendments to the Home Mortgage Disclosure Act

Contacts:

Monika Jansen, Policy Analyst, at (202) 898-7060 or mjansen@fdic.gov

Note:

FDIC Financial Institution Letters (FILs) may be accessed from the FDIC's website at www.fdic.gov/news/news/financial/2018/.

To receive FILs electronically, please visit www.fdic.gov/about/subscriptions/fil.html.

Paper copies may be obtained through the FDIC's Public Information Center, 3501 Fairfax Drive, E-1002, and Arlington, VA 22226 (877-275-3342 or 703-562-2200).