NCUA Issues Consumer Financial Protection Update on HMDA Interpretive Rule

On August 31, the Bureau of Consumer Financial Protection (BCFP) issued an interpretive and procedural rule to clarify and implement HMDA changes made in the regulatory relief package, S. 2155, which was passed earlier in the year. On the heels of BCFP’s clarification, the NCUA issued Consumer Financial Protection Update 18-01 to clarify a few points for credit unions.

First, NCUA covered transition issues and said that a credit union eligible for a partial HMDA exemption should report non-exempt data points in 2018, even if it collected all data points prior to the rule change. However, beginning in 2019, a credit union eligible for a partial exemption should collect and report the non-exempt data points.

Next, NCUA clarified that the HMDA changes do not affect the NCUA’s supervision approach to compliance with requirements for recording and reporting 2018 HMDA data. For HMDA data collected in 2018 and reported in 2019, the NCUA does not intend to cite violations for data errors found in the quarterly LARS, nor require data resubmission unless data errors are material.

You can find additional information about HMDA reporting requirements on NCUA’s Consumer Compliance Regulatory Resources page.