InfoSight Spotlight: Bureau clarifies how to take HMDA partial exemptions in light of S.2155 final rule

Earlier this month, CUNA hosted a webinar in conjunction with the BCFP on HMDA implementation, which focused on the more technical and operational aspects of the new HMDA rule following the Aug. 30, 2018, final rule implementing the S.2155 changes. A few take-aways from the webinar that credit unions should be aware of include the following:

  • Credit unions that qualify for the partial exemption from collecting and reporting certain HMDA data may take the exemption on any of the eligible data points, however you must take the exemption across the entire data point. If you don’t do this, you will get an error code of 710.
  • Note that data fields roll-up into data points, so you must take the partial exemption at the data point level. The example the bureau used was the credit score data point. If you are taking the partial exemption on that data point, that would also include the data fields within that data point such as applicant credit score, co-applicant credit score, version of credit score model, etc.)
  • Another question that came up was how to report the exemption code when the file does not have a co-applicant. The bureau stated that you should report the exemption code in the exemption field regardless, even if no co-applicant exists.
  • Additionally, you can take the partial exemptions on a single record, on some LAR records, or on all LAR records. It is up to the credit union to determine how many loans in the LAR to take the partial exemption on.
  • Exemption codes: for integer fields, you will enter ‘1111.’ For alphanumeric fields, you will enter ‘Exempt.’

If you missed CUNA’s HMDA webinar with the bureau, NCUA is also hosting a webinar where credit unions can learn more about recent changes to the Home Mortgage Disclosure Act and other federal consumer financial protection laws and regulations on Nov. 14 at 2 p.m.

Read the full InfoSight here.