Written by Eliott C. Ponte, Regulatory Compliance Counsel
Last week, the Consumer Financial Protection Bureau issued a one hundred and nine-page small entity compliance guide to accompany its other compliance resources to help financial institutions understand their obligations under the new Home Mortgage Disclosure Act (HMDA) rules.
The purpose of the small entity guide is to highlight information that credit unions might find helpful when implementing the new regulation. Among the information includes two chapters that help explain the changes to the institutional and transactional coverage tests. (NAFCU featured an article on this topic in the November Compliance Monitor). The small entity guide also includes a discussion (with helpful examples) on the additional data that must be collected, recorded, and reported for covered loans and applications under the new rule. Overall, the guide is a good starting point for determining what is necessary to be compliant under the new rule.
In addition to the compliance guide, the CFPB posted other helpful resources. Below are the links to the resources issued:
- Summary of reportable data
- Reporting “Not Applicable”
- HMDA Small Entity Compliance Guide
- HMDA key dates timeline
- HMDA executive summary
- Two HMDA Institutional coverage charts:
Unfortunately, the CFPB has yet to issue an updated version of Appendix A's instructions for completing the Loan Application Register, but has indicated that it will provide a "Filing Instruction Guide" for 2018's data collection requirements "in the future."
NAFCU is committed to helping credit unions comply with the new rule. As the effective date nears, NAFCU will continue to provide resources and information to help credit unions comply with the new regulation.
My wife and I rescued Macie from Lucky Dog on Halloween. She was a stray puppy picked up in June. She was found with a host of doggie issues, but now has a clean bill of health. We believe she is a Border Collie and Pointer mix, but are not sure. We have not done a DNA test, but we might consider it after Ollie’s results are announced. If any compliance reader has a similar looking dog, please write me.
Macie is very smart. She has learned her name, sit, lay-down, fetch, and drop-it.