NCUA provides an update on partial HMDA exemption

Sept. 10, 2018 -- ┬áToday, NCUA released Consumer Financial Protection Update 18-01. The update provides information about the BCFP’s 2018 HMDA Interpretive and Procedural Rule. The rule was released August 31 to clarify and implement changes made by section 104(a) of the Economic Growth, Regulatory Relief, and Consumer Protection Act to the Home Mortgage Disclosure Act (EGRRCPA, S. 2155). It became effective Sept. 7.

According to NCUA, a credit union eligible for a partial exemption should report non-exempt data points in 2018, even if it collected all data points prior to the rule change. As mentioned above the credit union may optionally report all data points. Beginning in 2019, a credit union eligible for a partial exemption should collect and report the non-exempt data points.

The agency further clarifies that the changes do not affect its supervision approach to compliance with requirements for recording and reporting 2018 HMDA data. For HMDA data collected in 2018 and reported in 2019, NCUA noted that it does not intend to cite violations for data errors found in the quarterly LARs, nor require data resubmission unless data errors are material.

NCUA Consumer Financial Protection Update 18-01