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FIL Letter Outlines HMDA Exemptions

FIL Letter Outlines HMDA Exemptions

Oct. 11, 2018 — The FDIC issued a Financial Institution Letter outlining the Bureau of Consumer Financial Protection’s previously released interpretive and procedural rule to implement and clarify the partial exemption from the Home Mortgage Disclosure Act adopted in the Economic Growth, Regulatory Relief, and Consumer Protection Act.

The Bureau’s rule clarifies which data points are covered, which loans and lines of credit count towards origination thresholds, and provides guidance on determining which CRA performance evaluations to consider when determining eligibility for partial exemptions.

Community banks may use a non-universal loan identifier for partially exempt transactions and may choose to report exempt data points as long as they report all data fields included in that data point, according to the Bureau. This Financial Institution Letter applies to all FDIC-supervised institutions subject to HMDA and Regulation C.

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