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Bureau Issues Rule Implementing S. 2155 HMDA Exemption

Sept. 04, 2018 — The Bureau of Consumer Financial Protection issued a rule implementing an ICBA-advocated provision of the S. 2155 regulatory relief law exempting many community banks from new Home Mortgage Disclosure Act reporting mandates.

Under the rule, banks with “satisfactory” CRA ratings that originate fewer than 500 closed-end mortgage loans or 500 open-ended lines of credit are exempt from HMDA data fields added by the bureau in 2015. Lenders are still required to collect and report the data fields in place prior to the 2015 rule.

The rule clarifies that only loans and lines of credit that are otherwise HMDA reportable count toward the exemption thresholds. It also details which data points are and are not covered by the exemption.

Inspired by ICBA’s Plan for Prosperity, the exemption was a key provision in the Economic Growth, Regulatory Relief, and Consumer Protection Act, which was signed into law in May. ICBA is reviewing the rule and updating its HMDA summary.

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