The CFPB Issues Annual Threshold Adjustments for HMDA

The CFPB amended the official commentary to Regulation C announcing their adjustment to asset-size exemption threshold.  HMDA (12 U.S.C. 2801-2810) requires most mortgage lenders located in MSAs to collect data about their housing related lending activity. Those institutions, that are not otherwise exempt, are compelled to report their lending activity data to their governing Federal agency and make the data available to the public. The CFPB is required annually (at the end of November) to adjust the asset threshold based on the year-to-year change in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W), not seasonally adjusted.  In 2016, $44 million was the threshold. The CPI-W at the end of November 2016 went up 0.8 percent and rounding to the nearest $1 million results in no change. As a result, the exemption threshold will remain at $44 million for 2017. Because of this, banks, savings associations, and credit unions with assets of $44 million or less as of December 31, 2016, are exempt from collecting data in 2017. Exemption from the requirement to collect data in 2017, however, does not relieve an institution’s responsibility to report data required to be collected in 2016.