NCUA issues CUNA-requested update on S. 2155 HMDA changes

The National Credit Union Administration (NCUA) issued information Thursday on changes to Home Mortgage Disclosure Act (HMDA) reporting required by the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155). CUNA has pushed regulators to issue guidance on the numerous regulatory relief provisions contained in the bill.

S. 2155 provides partial exemptions for some insured credit unions from certain HMDA requirements. According to NCUA, the Consumer Financial Protection Bureau is expected to provide further guidance on the applicability of S. 2155 to HMDA data collected in 2018.

  • Closed-end mortgage loans, if the credit union originated fewer than 500 closed-end mortgage loans in each of the two preceding calendar years; and
  • Open-end lines of credit, if the credit union originated fewer than 500 open-end lines of credit in each of the two preceding calendar years.

For closed-end mortgage loans or open-end lines of credit subject to the partial exemptions, S. 2155 states that the “requirements of [HMDA section 304(b)(5) and (6)]” shall not apply.

“Accordingly, for these transactions, those institutions are exempt from the collection, recording and reporting requirements for some, but not all, of the data points specified in current Regulation C,” NCUA’s bulletin says.

For all credit unions filing HMDA data collected in 2018, S. 2155 will not affect the format of loan/application registers (LAR). LARs will be formatted according to the previously released 2018 filing instructions guide (FIG) for HMDA data collected in 2018.

If a credit union does not report information for a certain data field due to S. 2155’s partial exemptions, the credit union will enter an exemption code for the field specified in a revised 2018 FIG that the Bureau expects to release later this summer.

LARs will be submitted to the same HMDA Platform. According to NCUA, a beta version of the HMDA Platform for submission of data collected in 2018 will be available later this year for filers to test.

NCUA states that these changes do not affect its supervision approach to compliance with requirements for recording and reporting 2018 HMDA data. More information is available in NCUA’s letter to credit unions on supervisory priorities for 2018 (17-CU-09).

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