And The Exemption Threshold For HMDA Filing For 2017 Is…

WASHINGTON—Credit unions with assets of less than $44 million as of Dec. 31, 2016 will remain exempt from data collection requirements of the Home Mortgage Disclosure Act in 2017, according to a CFPB final rule published Wednesday.

The CFPB is required to adjust the HMDA threshold yearly according to the annual percentage change in the average Consumer Price Index for Urban Wage Earners and Clerical Workers. The average saw a 0.8% increase for the 12-month period ending in November, meaning no change in the exemption threshold was necessary, NAFCU noted in its analysis.

Another CFPB update changes the asset-size threshold for lenders exempt from having to establish an escrow account for higher-priced mortgage loans under Regulation Z, which implements the Truth in Lending Act. The CFPB established a $2-billion threshold in 2013 and updates it yearly according to the same CPI standard used for HMDA. The asset-size threshold exemption is increasing from $2.052 billion to $2.069 billion for 2017, as of Dec. 31, NAFCU explained.

Both rules will be effective on Jan. 1 and apply to data collection and exemption eligibility during 2017; the Reg Z change will also apply during a grace period lasting until April 1, 2018.

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