HMDA Exemption Threshold up By $1M in 2012
Under HMDA in 2012, financial institutions with total assets of more than $41 million that have home or branch offices in defined metropolitan statistical areas must collect certain mortgage loan data and report it to federal regulators. The HMDA reporting threshold stood at $40 million in 2011.
HMDA thresholds are traditionally published in December of each year, but the CFPB did not set the 2012 threshold late last year. The Credit Union National Association (CUNA) raised this point with CFPB officials in early January, and asked that clarification concerning the 2012 threshold be provided as soon as possible.
The CFPB has issued an interim final rule on HMDA, and that rule became effective on Dec. 30, 2011. The interim final rule is substantially similar to the Federal Reserve's Regulation C, and CUNA will file an official comment letter with the CFPB on this interim final rule later this week.
The Dodd-Frank Act amended HMDA to require covered financial institutions to report the age of mortgagors and mortgage applicants, any points and fees payable at origination in connection with a mortgage, the difference between the annual percentage rate associated with a loan and a benchmark rate or rates for all loans, and the terms of a given mortgage loan, among other items.
According to the CFPB, these additional amendments required by the Dodd-Frank Act will be covered in future rulemakings by the agency, and are not made a part of the previously issued interim final rule or today's final rule.