As you know, in October 2015, the CFPB finalized amendments to the Home Mortgage Disclosure Act (“HMDA”). Among these were modifications to the government monitoring information (“GMI”) data collection requirements found in Appendix B to Reg C. In summary, Appendix B now contains very specific instructions on how a credit union must collect and report GMI about a HMDA reportable transaction. This includes procedures for both face-to-face as well as telephone, mail and online
applications. In addition, Appendix B also now provides for both aggregated and disaggregated categories of GMI. To help credit unions navigate the new HMDA GMI requirements, CUNA’s compliance team has developed a “HMDA GMI Collection” flow chart. This resource is available to CUNA member credit unions on the resource tab in the HMDA section of the E-Guide to Federal Laws and Regulations by clicking here. It is also available in the shared file library of CUNA’s Compliance Community by clicking here.
in Compliance & Regulatory News