BCFP Issues HMDA Rule


The Bureau of Consumer Financial Protection (BCFP) has issued an “interpretive and procedural rule” to implement the S. 2155 changes to Home Mortgage Disclosure Act (HMDA) reporting. The interpretive and procedural rule:

  • Clarifies that insured depository institutions and insured credit unions covered by a partial exemption have the option of reporting exempt data fields as long as they report all data fields within any exempt data point for which they report data;
  • Clarifies that only loans and lines of credit that are otherwise HMDA reportable count toward the thresholds for the partial exemptions;
  • Clarifies which of the data points in Regulation C are covered by the partial exemptions;
  • Designates a non-universal loan identifier for partially exempt transactions for institutions that choose not to report a universal loan identifier; and
  • Clarifies the exception to the partial exemptions for negative Community Reinvestment Act examination history.

At a later date, the Bureau anticipates that it will initiate a notice-and-comment rulemaking to incorporate these interpretations and procedures into Regulation C and further implement the Act.

You can access the rule on the Bureau’s website.

You can access the executive summary and Regulatory and Reporting Overview Reference Chart on the HMDA rule implementation webpage.

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