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Subject: Home Mortgage Disclosure Act
Date: April 23, 2012
To: Chief Executive Officers and Compliance Officers of All National Banks, Federal Savings Associations, Department and Division Heads, and All Examining Personnel
Description: Consumer Financial Protection Bureau Final Rule for Reporting Thresholds
On February 15, 2012, the Consumer Financial Protection Bureau (CFPB) published in the Federal Register the attached final rule amending the official commentary that interprets the requirements of Regulation C. By this amendment, the CFPB has raised the asset size exemption threshold to $41 million for depository institutions. Thus, institutions with assets of $41 million or less as of December 31, 2011, will not be required to collect Home Mortgage Disclosure Act (HMDA) data in 2012. The previous exemption threshold was $40 million. This revision is mandated by provisions of the Economic Growth and Regulatory Paperwork Reduction Act of 1996. The adjustment reflects changes based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers for the 12-month period ending in November 2011.
The adjustment is effective for data collection in 2012. An institution’s exemption from collecting data in 2012 does not affect its responsibility to report the data that it was required to collect in 2011.
Grovetta N. Gardineer