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Notice is coming a bit late in the year, but the Consumer Financial Protection Bureau has issued a final rule that applies a 2012 Home Mortgage Disclosure Act data collection exemption to credit unions with up to $41 million in assets as of Dec. 31, 2011.

Last year, credit unions with assets of $40 million or less were exempt from this Regulation C requirement. Reg C, transferred recently from the Federal Reserve Board to the CFPB, requires certain credit unions that issue mortgages to maintain a mortgage loan/application register and to submit the completed file to regulators in March of the following year.

The asset-size threshold for the exemption is reviewed annually, and the Fed usually announces any change at least several weeks before the beginning of the calendar year when it applies. The CFPB approved the final rule Feb. 3; the rule was published in Wedesday's Federal Register.

While the CFPB is in charge of the rulemaking, the Fed is still the agency collecting the HMDA files. NAFCU Director of Regulatory Compliance Steve Van Beek wrote about this yesterday on the NAFCU Compliance Blog. That entry also provides information on a report that offers an extensive overview of what goes into the loan/application register as well as what NCUA says in its February newsletter about fair lending exams.