WASHINGTON—The Bureau of Consumer Financial Protection issued a final rule at the end of August clarifying what changes in the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) mean for credit unions in terms of Home Mortgage Disclosure Act (HMDA) reporting.
The rule clarifies that the changes took effect when the bill was signed into law May 24, and also includes a list of the exact data points that are covered by the partial exemption.
Credit unions that do not meet the loan volume threshold of 500 open-end lines of credit and/or 500 closed-end loans do not need to report 26 of the data points, they only have to report 22 of them, CUNA explained.
A chart has been provided by the Bureau, which can be viewed here.
The rule also contains a change regarding the Universal Loan Identifier (ULI). Insured credit unions are not required to report a ULI for loans that are partially exempt (although they can voluntarily report the ULI if they prefer). But, credit unions that qualify for the partial exemption must still provide information so that each loan and application they report is identifiable for HMDA purposes, CUNA explained.
Other Provisions
The rule requires that credit unions must provide a non-ULI that complies with certain requirements for any partially exempt loan or application for which they do not report a ULI.
The ULI:
- May be composed of up to 22 characters
- May be composed of letters, numerals, or a combination thereof
- Must be unique within the credit union
- Must not include an information that could be used to correctly identify the applicant or borrower