ERIC S. BELSKY

DIRECTOR 

DIVISION OF CONSUMER AND 

COMMUNITY AFFAIRS

CA 18-6

 

July 5, 2018 

TO THE OFFICERS AND MANAGERS IN CHARGE OF CONSUMER AFFAIRS 

SECTIONS:

Applicability to Community Banking Organizations: This guidance applies to all institutions 

supervised by the Federal Reserve, including those with total consolidated assets of $10 billion 

or less.

SUBJECT: Statement on the Implementation of the Economic Growth, Regulatory Relief, 

and Consumer Protection Act Amendments to the Home Mortgage Disclosure Act

On May 24, 2018, the President signed the Economic Growth, Regulatory Relief, and 

Consumer Protection Act (the Act), a section of which amends the Home Mortgage Disclosure 

Act (HMDA).1

The Act provides partial exemptions for some insured depository institutions and insured 

credit unions from certain HMDA requirements.2 The partial exemptions are generally available 

to insured depository institutions and insured credit unions: 

• For closed-end mortgage loans, if the institution originated fewer than 500 closed-end 

mortgage loans in each of the two preceding calendar years. 

• For open-end lines of credit, if the institution originated fewer than 500 open-end lines of 

credit in each of the two preceding calendar years. 

For closed-end mortgage loans or open-end lines of credit subject to the partial 

exemptions, the Act states that the “requirements of [HMDA section 304(b)(5) and (6)]” shall 

not apply. Accordingly, for these transactions, those institutions are exempt from the collection, 

recording, and reporting requirements for some, but not all, of the data points specified in current 

Regulation C. 

 

1 HMDA is implemented by Regulation C, 12 CFR part 1003.

2 Pub. L. 115-174, section 104(a) (to be codified at 12 USC 2803).
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The Bureau of Consumer Financial Protection (Bureau) expects later this summer to 

provide further guidance on the applicability of the Act to HMDA data collected in 2018.3

2018 Loan/Application Registers (LARs) Formatting and Submission

For all institutions filing HMDA data collected in 2018, the Act will not affect LAR

formatting: 

• LARs will be formatted according to the previously released 2018 Filing Instructions 

Guide for HMDA Data Collected in 2018 (2018 FIG).4

 

• If an institution does not report information for a certain data field due to the Act’s partial 

exemptions, the institution will enter an exemption code for the field specified in a 

revised 2018 FIG that the Bureau expects to release later this summer. 

• All LARs will be submitted to the same HMDA Platform. A beta version of the HMDA 

Platform for submission of data collected in 2018 will be available later this year for 

filers to test.5

Supervisory Expectations 

As announced in December 2017, the Federal Reserve does not intend to require data 

resubmission for HMDA data collected in 2018 and reported in 2019 unless data errors are 

material. Furthermore, the Federal Reserve does not intend to assess penalties with respect to 

errors in data collected in 2018 and reported in 2019. Collection and submission of 2018 HMDA 

data will provide institutions with an opportunity to identify any gaps in their implementation of 

amended Regulation C and make improvements in their HMDA compliance management 

systems for future years. Any examinations of 2018 HMDA data will be diagnostic to help 

institutions identify compliance weaknesses and will credit good faith compliance efforts.

If you have any questions, please contact Amal Patel, Senior Supervisory Consumer 

Financial Services Analyst, at (202) 912-7879, or Tim Robertson, Manager, at (202) 452-2565. 

In addition, questions may be sent via the Board’s public website.6

 

Sincerely, 

Cross-reference:

• CA 17-4 “Expectations for Supervised Institutions Regarding Amended Regulation C” 

(December 21, 2017) 

 

3 The partial exemptions are not available to insured depository institutions that do not meet certain Community 

Reinvestment Act performance evaluation rating standards. Guidance will include information on how this 

provision will be implemented.

4 https://s3.amazonaws.com/cfpb-hmda-public/prod/help/2018-hmda-fig.pdf. 5 The FFIEC’s HMDA Platform and filing resources and tools are available at https://ffiec.cfpb.gov. 6 See http://www.federalreserve.gov/apps/contactus/feedback.aspx.