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CFPB Announces 3 New HMDA Exemption Threshold & Reminder on MSAs

1 min read
Jan 7, 2014

Every year, the Consumer Financial Protection Bureau (CFPB) reviews the asset-size exemption threshold for banks, savings associations, and credit unions under Regulation C, which implements the Home Mortgage Disclosure Act (HMDA).  On December 30th, the CFPB released the new threshold, with 3 reminders you need to know now.

The CFPB adjusts the asset-size exemption threshold yearly by the annual percentage in the Consumer Price Index for Urban Wage Earners and Clerical Workers.  Based on adjustments announced at the end of 2013, the asset-size exemption for banks, savings institutions, and credit unions will increase to $43 million (from last year's threshold of $42 million).  

As a result, these institutions with assets of $43 million or less as of December 31, 2013, are exempt from collecting HMDA Data in 2014.  An institution's exception from collecting data in 2014 does not affect its responsibility to report the data it was required to collect in 2013.

This brings up three quick HMDA reminders that should be on everyone's radar:

  1. HMDA Submission Date:  By March 1 of the following the calendar year for which the loan data are compiled, a financial institution shall submit its complete loan/application register.

  2. Public Disclosure Date for HMDA: The Federal Financial Institutions Examination Council (FFIEC) will prepare a HMDA disclosure statement from the data each financial institution submits. An institution shall make its disclosure statement available to the public at the institution's home office no later than three business days after receiving the disclosure statement from the FFIEC.  For reference purposes, these disclosure statements have been released around the third week in September for the past few years. 

  3. Geographic Changes - New MSAs for 2014:  The new MSA definitions released in February 2013 by The Office of Management and Budget (OMB) apply to HMDA data collected on or after January 1, 2014.

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