The Home Mortgage Disclosure Act (HMDA) requires credit unions to disclose certain information regarding loans originated or purchased by the credit union. HMDA is implemented by the CFPB's Regulation C which was recently amended to include home equity lines of credit, establish transactional thresholds for coverage, and expand the number of HMDA data points collected from credit unions. Most of the new HMDA requirements will become effective January 1, 2018.
Expansion of the HMDA data set to roughly 38 data points will likely necessitate major changes in the data collection processes, policies and procedures for many credit unions. Currently, more than 20% of NAFCU survey respondents manually collect data for most HMDA data points (May 2016 NAFCU Economic & CU Monitor data). Credit unions that are subject to the final regulation will need to have plans and processes in place well before the effective date.
Below you'll find credit union resources for HMDA/Regulation C compliance, including final rule summary, scope and applicability chart, insightful blog posts, articles and webcasts, to help you get up-to-speed.
Resources marked by * are member-only. If you are not a NAFCU member, learn more about membership.
NAFCU HMDA/Regulation C Final Rule Summary*
HMDA Consolidated Regulatory Text*
See what exactly changed in the rule text and when it is effective.
HMDA Scope & Applicability Chart*
A handy resource detailing the background, scope and exemptions for the new HMDA requirements under CFPB's Regulation C.
HMDA Data Points Chart*
Compare the difference between current and upcoming data points.
HMDA Action Taken and Date Chart*
A handy resource to help report an accurate date of action.
HMDA Reportable Purpose for Multipurpose Loans*
Categorize multipurpose loans at-a-glance.
Compliance Central Article: Preparing for HMDA - Do You Have a Legal Entity Identifier?
HMDA Final Rule Series: Reporting Data Under the Revised HMDA Rule*
HMDA Final Rule Series: Changes to the Institutional and Transactional Coverage Tests*
HMDA Final Rule Series: Understanding HMDA's New Transactional Scope*
Compliance Central Article: The HMDA Final Rule Is Knocking on Your Credit Union's Door
Follow all HMDA-related blog posts on The NAFCU Compliance Blog
Home Mortgage Disclosure Act rule implementation page
Includes small entity compliance guide, executive summary and institutional coverage charts.