Regulatory Alerts2018-07-05
Statement on the Implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act Amendments to the Home Mortgage Disclosure Act
The Federal Reserve issued guidance clarifying that the Economic Growth, Regulatory Relief, and Consumer Protection Act provides partial HMDA exemptions for institutions originating fewer than 500 loans or lines of credit in each of the two preceding years. The document mandates that 2018 Loan/Application Registers retain their original formatting while requiring specific exemption codes for unreported data fields, with detailed instructions expected later in the summer. Furthermore, the Federal Reserve announced it will not require data resubmission or assess penalties for 2018 HMDA errors, treating examinations as diagnostic opportunities to support good faith compliance efforts.
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