NCUA HMDA and Consumer Compliance Regulatory Update Webinar (11/14/2018)
Good. Afternoon and, welcome to the NCUA, webinar, on recent, changes to the home mortgage, disclosure. Act for Honda and other, consumer compliance, laws, my. Name is Joe Goldberg. I'm the director of the division, of consumer compliance. Policy, and outreach in the NCUA's, Office, of Consumer Financial Protection. My. Division works on policy, issues related to standard, consumer protection, matters and also. Conducts, the agency's, fair lending program, which, includes supervision. For compliance, with Honda as. You. May be aware this, year brought many changes to, fair lending and consumer compliance laws, we. Are presenting this webinar to, provide an update on the most significant, ones, we. Will first cover the changes, Congress made earlier this year to HMDA reporting. The. Presenters, will also, discuss some observations. By field staff during their limited hunger reviews, in 2018. In. The. Second half we, will discuss many of the amendments to consumer, compliance laws, resulting. From congressional action. In May of 2018, if. Time. Permits we will answer questions you, submit during the webinar. Our. Goal today is to provide you with information and, resources you, can use to ensure your credit union remains, in compliance, with all applicable, consumer, compliance laws and regulations, and. Now. I will turn it over to grace Lee who is the moderator, in one of the presenters of today's webinar. Thank. You Jo i'm grace. Lee consumer. Compliance policy, and outreach specialist. Today's. Webinar is on the Home Mortgage, Disclosure Act also, known as HMDA as implemented. By regulation. C and the. Economic, growth, regulatory. Relief and consumer. Protection act we. Hope to provide helpful information about, these important, topics. Before. We get into the substance of today's webinar I have, a few administrative announcements, related. To the webcast functionality. First. Please, make sure the volume on your computer is turned up. That you can hear the webcast, if you. Have trouble viewing a slide click. On the enlarge slides button on the bottom of the console, please. Allow pop-ups from the website a, screen. Resolution, of 1024. By, 768, or, higher will. Let you see the slides, you. Can submit a question at, any time during. The webcast in the ask a question box. We. Have set aside time at the, end of today's presentation. To. Address questions is, time permits, mostly. Focusing, on questions we received in advance, thanks. To all of you who, sent in questions. If. Your question is not answered during the webcast please. Email, us at OSI. FP. BCP. O mail, at ncua.gov. That's. OCSP. BCP. O mail, at ncua.gov. This. Webinar will be archived, in approximately. Three, weeks after, the live event, please. Note that we're presenting this webinar for. Informational. Purposes only, to. Enhance understanding of, the statutes, and regulations and, CUA. Administers, the. Next thing we will see is the agenda, on slide 2 in. The. HMDA portion of the webinar we, will cover. Changes. 200, data collection, and reporting effective. January, 1st 2018. And. The. Bureau of Consumer Financial, Protection. Or. The bureau, interpretive. And procedural, rule issued, on August 31st. 2018. Clarify. Changes, made in the economic, growth' regulatory. Relief and. Consumer Protection Act, and the legislative. Update portion, of the webinar we. Cover the 2018, changes. To, various Consumer, Financial Protection laws. Now. Matt, Nixon, program, officer, with, the office of consumer financial, protections, division. Of consumer compliance, policy, and outreach will. Discuss the HMDA portion, of the webinar. Thank. You grace in this, portion of the webinar I'll, be covering. Changes. Made to Honda, and regulation, see data collection, and reporting requirements. Made. By the dodd-frank act, and the bureau, changes. To HMDA data collection. And reporting, effective. January, 1st 2018. The. Bureau's, interpretive. And procedural, rule issued. On August 31st, 2018. The. Clarify, changes, made by the economic. Growth' regulatory. Relief and Consumer. Protection Act. Recent. Changes to HMDA and Regulation. C, regarding. Exemptions. Allowed for, collection, and reporting of, certain, new data points, and. NCUA's. Ongoing. Effort to review and test HMDA, data, reporting. In credit, unions. But. Before, we dive into these topics I'll give a brief overview of HMDA. And its, implementing. Regulation. Regulation, C. The. Home Mortgage Disclosure Act, or, HMDA, requires. Certain, financial, institutions. To. Collect report. And disclose, information about. Their mortgage lending, activity. Under. Was originally, enacted by the Congress in, 1975. One. Statutory. Purpose, of HMDA is to provide the public with information that, will help show, whether. Financial, institutions. Are serving, the housing, credit needs of, the communities, and neighborhoods, in which they are located a.
Second. Statutory, purpose, is to aid public, officials, in distributing. Public, sector investment. So, as to attract private investment. To areas, where it is needed, the. Financial, institutions. Reform recovery and, Enforcement, Act. Of 1989. Ireia. Amended. HMDA to, require, the collection, and disclosure, of data about. Applicant. And borrower, characteristics. Assist. In identifying possible. Discrimination, taury lending, patterns and. Help. Enforce, anti-discrimination. Statutes. Regulation. C implements. HMDA. The. Dodd-frank Wall Street Reform, and, Consumer Protection, Act. Or the dodd-frank, act, amended. HMDA to among other things require. Reporting. Of additional, data points. Transfer. HMDA, rulemaking, authority from, the Federal Reserve Board, to the bureau and. Transfer. Regulation. C rulemaking. Authority, to the bureau. In. August 2014, the, bureau, proposed, amendments. To regulation. C to implement, the dodd-frank act, changes. Require. Collection. Recording. And reporting, of additional, information to, further, Hondas purposes, and. To modernize, the manner in which covered, institutions. Report, on the data, the. Bureau published, final, amendments, to regulation. C in October. 2015. Under. That rule, financial. Institutions. Continue, to report data regarding. Loan originations. Applications. And loan purchases. The. Bureau's rule changed. The, types of financial, institutions. Subject, to regulation. C, the. Types of transactions. Subject to regulation, see, the. Data financial, institutions. Are required, to collect record. And report. Pursuant. To regulation. C and. The. Processes. For reporting, and disclosing. HMDA data. Data. Is now submitted, electronically. To, the bureau on behalf. Of the appropriate, federal agency. Associated. With reporter, and much. Of the data are made available to, the public on both, an aggregate, and a loan level basis. The. Next slide outlines, the loan volume thresholds. Effective, January, 1st 2018. The. Loan volume thresholds. Require, an institution. Originating. At least 25, closed-in, mortgages, or, at least 500. Open den lines of credit in each. Of the two preceding calendar, years to. Report HMDA data, this. Is the case if the institution meets. All of the other criteria for, institutional. Coverage, which, I'll cover at the end of this slide, the. 500. Opened n line of credit, threshold, is temporary. And applies. In, calendar, years, 2018. And 2019. Effective. January, 1st, 2020. The. Opened n lines of credit threshold, reverts, to 100. In each, of the two preceding calendar years, the. Threshold, stated, in the 2015. Final, rule the. Other institutional. Coverage, criteria, do, not change, in 2020. Thus. Effective. January, 1st 2020. A, depository. Financial, institution. Is subject. To regulation, C, if, it originated, at least. 25, covered, closed in mortgage, loans in each, of the preceding. Two calendar, years or. At. Least, 100. Covered, opened, in lines of credit in each, of the two preceding, calendar years, and meets. The other applicable, coverage, criteria. The. 2015. Rule also, included. A separate, test to. Exclude, institutions. That, offer opened. In lines of credit, and no. Closed, in mortgage, loans from.
Institutional. Coverage, in other. Words. Institutions. That only, offer he locks are not required. To report even. If they originate, more than 500. He locks annually. Because. An institution. Still, must. Originate at, least one home purchase, loan or. Refinancing. Of a home purchase loan secured. By a first lien on a into four unit dwelling, in order. To be a covered, institution. The. Other coverage, criteria. Includes. Having. A home or branch office, in a Metropolitan, Statistical Area as, of. The prior December, 31st, and. Meeting. The applicable total. Asset, threshold, as of, the prior December, 31st. Currently. The asset, threshold, is 45, million. Let's. Look at some examples, to help understand, this. This. Slide provides HMDA, institutional. Coverage, threshold. Examples, as. Mentioned. On the previous slide, credit. Unions do not have to collect and report HMDA. Data for. Closed in mortgage, loans or, the, current reporting, year if they did not originate. At least 25, closed, in mortgage, loans in each of the prior two years and. Credit. Unions do not have to collect and report HMDA, data for. Open the end lines of credit, in the. Current reporting, year if they, did not originate. At least 500. Opened in lines of credit in each of the prior, two years. In. Example, a the. Credit union must only report, open, the n lines of credit, because, the credit union originated. At least 500. Opened in lines of credit, in each, of the prior two years but. Did not originate. At least 25, closed, in mortgage, loans in each of the prior two years an. Example. B only. Closed, in mortgage, loans must be reported in. Example. C both. Closed, in mortgage, loans and open. The in lines of credit must be reported and. In. Example, D the, credit union is not required, to file a HMDA, loan application. Register. However. The. Credit union may elect to optionally. Report, since. Loan volume is near, the reporting, threshold for both closed in mortgage, loans and opened. In lines of credit. In. January. 2018, the. Bureau modified. Regulation. C regarding. Government monitoring, information, or GMI. DMI. Is data collected, and reported about, the applicants. The. Changes, also affected, the types of loans to be reported. Although. Originators. Who, are not HMDA, filers, also, collect, GMI, our. Discussion. Is only in the context, of home defiling. First. I'll discuss, new requirements. For collection, of GMI, on ethnicity. Race. And sex. The. Final, rule requires, financial. Institutions. To report whether. Ethnicity. Race or sex, information. Was. Collected on the basis, of visual, odds are observations. Or surname, when. An application, is taken in person, and the. Applicant, does not provide, the information. You. Likely, are already, familiar with the ethnicity, and race categories. That, I'm referring to in this presentation, as, aggregated. Categories, or. Ethnicity. The, aggregated, categories. Are. Hispanic. Or Latino, and not. Hispanic. Or Latino. Or. Race the. Aggregated, categories. Are, American. Indian or Alaskan. Native. Asian. Black. Or African, American, Native. Hawaiian or, other Pacific, Islander. And white. The. Final, rule added. For. Disaggregated. Ethnicity. And 12. Disaggregated. Race categories. For, information. Provided, by applicants. Financial. Institutions. Must, permit applicants. To self-identify. Using. Disaggregated. Ethnic, and racial sub, categories. And must. Report, the disaggregated. Information. Applicants. Provide. For. Example the. Aggregated, ethnicity. Category. Of Hispanic. Or Latino, must. Be broken down into the subcategories. Of Mexican. Order. Rican, Cuban, or other, Hispanic. Or Latino, the. Aggregated, race category. Of Asian, and Native. Hawaiian. Or other Pacific, Islander. Categories. Also, must, be broken down into, their respective, disaggregated. Sub categories. When. Race and ethnicity, data is completed. By the financial, institution, the. Final, rule retains, the current requirements. Requiring. Financial, institutions. To provide. Only, aggregated. Ethnic, or racial data, the. Final, rule does not require. Or permit. Financial. Institutions. To use the, disaggregated. Sub categories. When, identifying, the applicants, ethnicity, and race. Based. On visual observation. Or surname. In. The, January, 2018, revision. The, bureau also, includes, a new dwelling, secured, standard, for, all loans or, lines of credit, for personal, family or household. Purposes. So. Most. Consumer. Purpose, transactions.
Including. Closed in home equity loans, home. Equity lines, of credit and. Reverse. Mortgages. Are subject. To the regulation. Most. Commercial. Purpose. Transactions. Are subject, to the regulation. Only, if they are for the purpose of home purchase, home, improvement. Or refinancing. The. Final, rule excludes. From coverage, home, improvement. Loans not. Secured, by a dwelling that, is. Unsecured. Home improvement, loans or. Home Improvement loans. Secured. By some other type of collateral, and all. Agricultural. Purpose, loans and lines of credit. The. 2015. HMDA rule, significantly. Changes, the data points, HMDA filers, are required, to collect and report or. 2018. And, thereafter. Prior. To the 2018, reporting. Year financial. Institutions. Were required, to collect and report 22, data points, and had. The option, of reporting, reasons, for denial or, a total. Of 23 data points. The. Dodd-frank act, revised, HMDA reporting, requirements. To, align. Current, humba fields, with, industry, data standards. And close, information. Gaps, the. First table shows the data points, required in. 2017. And prior, reporting. Years, the. Second, table shows the data points, added, by the dodd-frank act, for, 2018, and, after. Reporting, years, the. Third table shows the data points, added, under the bureau's discretionary. Authority for. 2018, and after, reporting, years, note. For. 2017. And prior reporting. Years. Reporting. Of reasons for denial had been optional, and. Reporting. Of approved but not accepted, applications, and, HELOC, applications. For. Home improvement, purposes had. Also, been optional. The. 2015. HMDA rule required. Credit, unions to collect, record, and report, information. On a total. Of 48 data points, there. Are 25, new data points, 11. New data points, identified, in the dodd-frank act, and 14. New data points, added by the bureau under their discretionary. Authority. There. Are 23. Existing. Data points, the, final, rule modified. 14, existing. Data points, the. Final, rule left, 9 data points, unchanged. And. Changed. Reporting, of reasons, for denial from. Optional, to mandatory and. Eliminated. Reporting, of metropolitan, statistical, areas. And, metropolitan. Divisions. When. Reporting, reasons, for denial credit. Unions, now, have the option of reporting, for denial, reasons, instead, of three. Credit. Unions must report all 48, data points, on their 2018. HMDA, lar due, March 1st 2019. Unless. They qualify, for a partial, exemption, I'll. Discuss, partial, exemption, requirements. Later, in the presentation. The. Data points, required to be reported under the 2015. Final, rule are grouped. Into four broad categories. Information. About applicants. Borrowers. And the underwriting, process. Such. As age credit. Score debt. To income ratio. And, automated. Underwriting system. Results. Information. About, the property securing. The loan such. As construction, method. Property. Value, and additional. Information about, manufactured. And multi-family, housing. Information. About the features of the loan such. As additional, pricing, information. Loan. Term interest. Rate introductory. Rate period non. Amortized, and. The, type of loan and. Certain. Unique identifiers. Such. As a universal. Loan identifier. Property. Address, loan. Originator. Identifier. And a, legal entity identifier, for. The financial, institution. The. Next five slides lists. All of the HMDA data points. Within the four categories. Information. About applicants. Borrowers. And the. Underwriting, process, include. The following data points. Applicant. Ethnicity. Race, and sex. Applicant. Age. Applicant. Income. Applicant. Debt to income ratio. And credit, score, the. Name of the automated, underwriting system. Used, to evaluate the, application. If any, the. Application. Channel. Indicating. Whether or not the application, was submitted to the credit union directly. The. Reason, or reasons for, denial if the application, was denied, the. Application. Date and. Whether. The transaction. Involved, a pre-approval, request. Information. About, the property, securing, the loan includes. The following data points. Property. Location, by, state, county. And census, tract. Lien. Status. Value. Of the property, relied on that, secures, the loan. Combined. Loan-to-value, ratio. Whether. The dwelling, is site built or a manufactured. Home if. A manufactured. Home whether. The loan is secured, by a manufactured. Home and land, or, a manufactured. Home and, not land. Information. About the applicants. Or borrowers. Ownership. Or, leasehold. Interest in, the land where. The manufactured. Home is located. Number. Of individual, individual. Dwelling, units related, to the property.
Number. Of individual. Dwelling, units related to the property, that our income, restricted. Under federal. State or local affordable. Housing, programs, and. Whether. The property, will be used as a principal, residence. Second. Residence, or investment. Property. This. Is the first of two slides discussing. Loan features. Reportable. Loan features, include. Loan. Type that. Is whether the loan or application. Is insured. By the FHA, or. Guaranteed. By the VA, Rural. Housing service, or Farm, Service, Agency. Whether. The transaction. Is for home purchase, home improvement. Refinancing. A shout. Refinancing. Or another, purpose. The. Loan amount. Action. Taken, an action, taken, date type. Of purchaser, if any. Rate. Spread, the. Difference, between the annual percentage rate, and average, prime, offer rate for, a comparable, transaction. Whether. The loan is a high-cost, mortgage, under, the home ownership and, equity Protection. Act the, total. Loan costs. Or total, points and fees charged, and. Total. Borrower paid origination. Charges. Reportable. Loan features, also include. Points. Paid to the credit union to reduce the interest rate, amount. Of lender, credits. Interest. Rate on the approved application. Or loan term. In months, of any prepayment, penalty. Number. Of months, after which the legal obligation. Will mature or, terminate. Number. Of months, until the first date the interest, rate may change. Whether. The transaction. Involves. A balloon payment interest. Only interest-only. Payments. Negative. Amortization or. Any, other type of non, amortized. Whether. The transaction. Is for a reverse, mortgage. Whether. The transaction. Is for an open end line of credit, and whether. The transaction. Is primarily. For. A business, or commercial. Purpose. Finally. Some. HMDA, data points. Provide, identifying. Information. About, the application. Or loan, the. Legal entity identifier is. An identifier, issued, to the financial, institution. By, a utility. Endorsed. By the global, le I foundation. Or le, I regulatory. Oversight, committee. The. Universal. Loan identifier. Is an identifier. Assigned. To identify, and retrieve. A, loan, or application. The. Physical, address of the property securing. The loan and, the. National, mortgage licensing. System, and registry. Identifier, for. The mortgage loan originator. On. May 24th. 2018. The. President, signed the economic, growth' regulatory. Relief, and Consumer. Protection Act, into, law, it. Is sometimes, referred to by its bill, number, s. 21:55. Section. 104, a of s. 21:55. Amend. Section, 304, I of, HMDA, by. Adding, partial, exemptions, from. Hum does requirements. For certain, insured, credit unions. New. HMDA section, 304. I1. Added. By s, 21:55. Provides. That the requirements. Of HMDA, sections, 304. B 5 and 6, shall. Not apply with respect to closed in mortgage, loans of, an insured, credit union, if it, originated. Fewer than 500. Closed in mortgage, loans in, each, of the two preceding calendar years. Similarly. New. Honda section 304. I2. Provides. That the requirements. Of HMDA section, 304. B 5 and 6 shall. Not apply with respect to, open, the in lines of credit of an insured, credit union.
If, It originated, fewer than 500. Opened, in lines of credit in each. Of the two preceding calendar years. The. Bureau issued an in, interpretive. And procedural. Rule on August. 31st 2018. Becoming. Effective September, 7th. 2018. The. Rule clarifies, and. Implements, changes, made to Honda, and Regulation. C by. S. 21:55. The. Interpretive, rule clarifies. That. Only closed, in mortgage, loans and opened, in lines of credit, that are. Otherwise reportable. Under Regulation. C out. Toward, the thresholds. For the partial exemptions, named in s 21:55. Permits. The use of a unique. Non-universal. Loan identifier. For. Certain, partially, exempt transactions. And, includes. Parameters. On what, constitutes. An allowable, non, universal, loan identifier. Clarifies. That. Insured, credit unions, qualifying, for a partial, exemption, may, optionally. Report, exempt, data points, so, long as they report all data, fields. That the data point comprises. The. Rule identifies, the seven data points, that contain, multiple data, fields, and. Includes. A table, identifying. The 26, data points, in regulation. C covered. By the partial, exemptions, named in s21. 55. NCUA's. Office. Of Consumer Financial Protection. Issued. Consumer, Financial Protection update. 18-0. 1, dated. September, 10th, 2018. Discussing. Key provisions, of the rule. For. Purposes, of the partial, exemptions, the. Interpretive, rule clarifies. That. Closed-in mortgage, loan and open. The in line of credit, mean, only, those loans or lines of credit, secured. By a dwelling that. Would otherwise be reportable, under, HMDA. Credit. Unions, may use either a universal. Loan identifier. Or non, Universal. Loan identifier, for applications. And loans. Qualifying. For a partial, exemption, a, universal. Loan identifier. Is defined, in HMDA, a non. Universal, loan identifier. May be comprised, of up, to 22, characters, to. Identify. The covered, loan or application. Which. May. Be letters, numerals, or, a combination, of, letters and numerals. Must. Be unique, within the insured, depository. Institution. Or insured. Credit union, and. Must. Not include any information that, could be used to directly, identify. The applicant. Or borrower. An. Insured.
Depository. Institution. Or insured, credit union, as the. Option, to voluntarily, report, exempt, data points, or transactions. That qualify, for a partial, exemption. However. An insured. Depository. Institution. Or insured, credit union, that, opts, to voluntarily, report, an exempt, data point must. Report, report. All data, fields, that, the specific, data point comprises. There. Are, of 26, data points, covered. Under the partial, exemption, this. Slide lists, the first 13 data points, that credit unions do, not have to collect and report if. The, credit union is exempt, the. Exempt, data points, are. Universal. Loan identifiers. Property. Address, rate. Spread, credit. Score. Mandatorily. Reported reasons. For denial. Total. Loan costs, or total, points and fees. Origination. Charges. Discount. Points, lender. Credits. Interest. Rate. Prepayment. Penalty, term debt. To income ratio. Combined. Loan-to-value, ratio. The. Remaining, 13, data points, which are exempted. Are, loan. Term. Introductory. Rate period. Non. Amortize. Infuse. Property. Value. Manufactured. Home secured, property, type. Manufactured. Home land property, interest. Multifamily. Affordable. Units. Application. Channel. Mortgage. Loan originator identifiers. Automated. Underwriting system. Reverse. Mortgage, flag. Opened. In line of credit flag and. Business. Or commercial, purpose flag. This. Slide provide, partial, exemption, examples, as we. Go through these keep in mind that, credit unions do, not have to collect and report the, twenty six data points, subject. To the partial, exemption, or the, current reporting, year if, they, did not originate. At least 500, closed-in mortgages, in each. Of the prior two years, the. Same partial, exemption, applies to open the in lines of credit, if they, did not originate, at least 500, open the in lines of credit, in each. Of the prior two years. In. Example, a the. Credit union originated. At least 500. Closed in mortgage, loans and at, least 500. Opened in lines of credit in, each, of the prior two years the. Credit union does, not qualify for a partial, exemption, for either loan type it. Must collect and report all data, points, including. The 26 data points, covered under the partial, exemption, for, both closed-in, mortgages, and, opened. In lines of credit. In. Example, B the. Credit union originated. At least 500. Opened in lines of credit, in each. Of the prior two years, but. Did not originate. At least 500. Closed in mortgages, mortgage, loans in each of the prior two years, the. Partial, exemption, applies, only, to closed, in mortgage, loans the. Credit union is required, to report HMDA, data for. Closed in mortgage, loans because. It originated, 25, or more in, the two preceding. Calendar years. But. It is exempt, from reporting, the 26, data points, covered, under, the partial, exemption, for closing mortgage, loans, the. Credit union collects, and reports all, data, points, including. The 26, data points, covered under the partial exemption, or, open, the n lines of credit. In. Sample see, both. Loan types are covered, by the partial, exemption, the, credit union is exempt, from reporting, the 26, data points, covered under the partial, exemption, foreclosed. In mortgage, loans and opened. In lines of credit the. Credit union will report, from the data for closed in mortgage, loans because. It originated, 25. Or more in the two preceding. Calendar years, the. Credit union is not required, to report any, data for, opened in lines of credit. However. As a reminder, the. Bureau temporarily. Increased. The opened end lines of credit threshold, from. 100. To 500, for. Calendar, years 2018. And 2019. If. This. Example, were given in 2020. The, credit union would still qualify for a partial, exemption, for, opened in lines of credit, but, would be required, to report, all data points, not covered, by the partial, exemption, because. It originated, 100 or, more open in lines of credit in the, two preceding. Calendar years. In. Example, D the, credit union originated. At least 500. Closed in mortgage, loans in each, of the prior two years, but. Did not originate. At least 500. Opened in lines of credit, over the same period, the, partial, exemption, applies only, to opened, in lines of credit the. Credit union collects and reports all, of that appoints, including. The 26, data points, covered under the partial exemption, or, closed, in mortgage, loans as, with. Example, C the, credit union is not required, to report any data, for opened in lines of credit, but. Would, report, data points, not covered, by the partial, exemption, if, this, example, was given in 2020. Or later, because. Opened, in lines of credit, exceed, 100. Annually. While. This may seem confusing, we. Have a number of resources, to help you understand. HMDA requirements. We, provide, a list of those resources, at the, end of this presentation. NCUA. Examiner's. Are. Performing. Limited, reviews, of 2018. HMDA, loan application. Register, data during. On-site.
Exams, At Federal, Credit Union's, this year. Examiner's. Review, a sample, of 10 applications. From. The Credit Union's 2018. Humble are using. The testing, spreadsheet, provided, in Ares and. Completes. The HMDA Ares questionnaire. The. Goal of the limited, reviews, is to determine. If credit, unions are making a good-faith effort, to comply, with. New Honda, rules, we. Are not citing, violations. For data collected. But, not yet filed. Based. On HMDA reviews that were completed, in 2018. We. Believe credit, unions are generally, making a good-faith effort, to comply with new requirements. Some. Common, issues we noted, include. 1, as. Of. The exam dates, some. Vendors, had not yet made available platforms. To collect new Honda data fields. We. Believe many have since corrected, this, but. For, the credit unions who rely on third-party, vendors. To, collect, record. Or, report, HMDA, data which. Is the majority of you you. Should be working with your vendors now to ensure a smooth, 2018. Reporting, cycle. 2. Examiner's. Noted, several instances, where, data. Was not mapped, correctly, between. Loan, and HMDA platforms. Credit. Unions should be test checking, the accuracy of map data. 3. Regulation. C, requires. Financial. Institutions. To record HMDA, data on. A, loan application, register. Within. 30 calendar days, after. The end of the calendar quarter in which final. Action, is taken, such. As origination, or denial. Some. Credit unions are, not complying, with regulation. C's quarterly. Recording, requirement. And finally. For. We. Were unable to conclude anything. About the types of individual. Errors noted. Other. Than to say that they seem to be randomly, dispersed. Credit. Unions did not appear to be having difficulty, with. Any particular, data field, or fields. That. Concludes, my portion of today's webinar, I will, now turn it over to Al Brantley, to, provide a legislative. Update. Thank. You Matt I'm al Brantley, program, officer, in the Office of Consumer Financial Protection Division. Of consumer compliance, policy and outreach grace. And I will now cover the changes, s 21:55. Made. To various consumer, financial protection laws, the. Section numbers on the slides refer, to this section of s 21:55, where. The change is found, you. Should refer to s 21:55. Itself, to see which part of an existing, law the section, amends, we. Provide a link to s 21:55. In the reference section of, the presentation. In. Addition, to HMDA s 21:55. Amended, several other mortgage, rules providing. Regulatory relief or exemptions. For eligible, credit unions. We. Will focus on four sections, of s 21:55. Addressing. Mortgage rules with consumer, compliance implications. The. Provisions, in three of these sections, have been in effect since May 24th, 2018. One. Section, however requires, the bureau to, first issue a conforming, regulation. This. Slide lists topics, covered by the four sections. Section. 101 amends. The Truth in Lending Act to, create a new safe harbor category, of qualified, mortgage, or QM, loans or. Originate, our obligations, held in portfolio, by. The originator. This.
Provision, Is limited to, ensure depositories. Including. Credit unions with, less than 10 billion and assets, to. Be, eligible, and insured credit union must consider, and document, a borrower's, debts, income. And other financial resources and, the. Loan would satisfy certain, product, feature restrictions. Assessment. Of the borrower's ability to repay the loan is less prescriptive than, the, small credit or QM. The. Qualifier, for this new safe harbor category, insured. Credit unions, are not required, to follow appendix, q of Regulation, Z this. Provision, allows, for multiple methods, of documentation, of borrower's. Debts income. And other resources. The. Loan will satisfy fewer, products feature restrictions. Compared, to the small creditor QM. Applicable. Requirements include, points, and fees limits no. Negative. Amortization no. Interest only terms and prepayment. Penalty limits. Remember. Federal credit unions are prohibited, from imposing. A pre panel prepayment, penalty. Although. Safe, harbor is intended, to apply to loans held in portfolio it. Remains available under, limited circumstances if. The loan is sold a signed, or transferred. These. Circumstances include. I, transfer. Resulting, from failure or merger, of the insured credit union a. Transfer. To an insured depository, institution. With less than 10 billion in assets and retained. In portfolio. By, the transferee. Institution. Or. A, transfer, to a wholly owned subsidiary, of the insured, credit union, and the. Loan is considered an asset, of the credit union for regulatory accounting, purposes. This. Slide can, the small creditor QM, to the section 101 provisions. Section. 101 allows, larger, credit unions to use the portfolio compliance. Category, the. Asset cap of ten billion dollars as opposed, to the two billion asset, cap for the small creditor, of QM. This. New QM, category, is available only to insured banks and credit unions non. Depository. Institutions, or lenders are, excluded. Notably. The section 101 safe, harbor has more restrictive, portfolio, requirements. Requiring. Credit unions to hold the loan in portfolio. Generally. For the life of the loan rather, than, for just three years. However. The section 101 safe harbor, has more relaxed, loan criteria. Insured. Credit unions must comply with some product feature restrictions. But. Those restrictions are less stringent than, under the small creditor or portfolio, QM category. Additionally. Section, 101 relaxes. Underwriting, criteria. Requiring. Credit unions to consider and document, a borrower's, debts income. And other financial resources in accordance. With less prescriptive guidance then. Is required under the other QM category. Section. 103, amends. Title 11 of the financial, institutions reform, recovery and. Enforcement Act, or Faria. Korea. Requires, NCUA, and other federal banking agencies to, prescribe appropriate, standards, the, real estate appraisals, covering. Agency, approved and regulated financial, transactions. And describing. When the services, an appraiser is required. Interagency. Appraisal and evaluation guidelines. Were jointly issued on December 2nd 2010. NCUA. Issued a proposed rule on October, 3rd 2018. To, amend the agency's, real estate appraisals, regulation, in, conformity. With the faria amendment, and to, accomplish a few other objectives. Comments. Are due by December, 3rd 2018. The. Faria amendment, imposes the transaction. Value threshold and, certain, criteria, to. Exempt real estate transactions. In rural areas, from, appraisal, requirements. Mortgages. Under $400,000. May be exempt, from appraisal, requirements when. A licensed, or certified appraiser. Cannot, be found in a timely manner to. Take, advantage of the exemption, the, credit union originating, the mortgage must contact. At least three appraisers, from its approved list. Document. That none of the contacted, appraisers, is available, within five business days beyond. Reasonable. Fee and timeliness, standards and. Be. Subject to oversight by, NCUA. Notably. The exemption, does not apply to high-cost. Mortgage, loans also, known as Hawaii loans as defined. In the Truth in Lending Act. If. A qualifying, loan is sold or transferred the, exemption, is unavailable, except, in limited circumstances. Those. Include, a transfer. Due to failure, or merger, of the mortgage, originator. Transfer. To another federally, regulated entity. And retained, in portfolio, or, transfer. To a wholly owned subsidiary, and, reported.
As An asset of the mortgage originator. NCUA. Retains, authority to require an appraisal for safety and soundness concerns, a credit. Union making, a mortgage loan without an appraisal may. Be limited, in its ability to sell that obligation. Overall. The section 103 waiver provision, reduces. A regulatory, hurdle for credit unions in rural areas, where. State license, or state certified, appraisers, or sometimes difficult to find or unable. To complete an appraisal, in a reasonable amount of time to. Close on a mortgage. Section. 108 amends, the Truth in Lending Act, and adds. New criteria. For a consumer credit transaction. Secured. By our principal dwelling could, be exempt from escrow, requirements, the. Provisions, are not effective, until the bureau issues or conforming, regulation. The changes establish, a broad exemption, from some escrow requirements with different criteria than, the previous, exemption. Under. S 21:55. Credit, unions with assets of 10 billion or less that together, with their affiliates. Originated. 1,000, or fewer firstly, mortgages, during, the preceding, calendar year may, qualify. Under. The bureau's existing, escrow rule exemptions. Are provided, for credit unions that have less than two billion in total assets and extend. Two thousand or fewer mortgages, other. Restrictions, also apply. Section. 108, imposes. Three additional requirements, for eligibility. The. Credit union extended, a consumer, loan secured. By a dwelling in, a rural, or underserved area, in the, last or previous two years depending, on one in the year the subject loan is made the. Credit union generally does not establish and, maintain escrow, accounts, and. Add consummation. The, loan is not subject, to a commitment, be, acquired by our person who is ineligible, for, the same exemption. The. Bureau's fall. 2018. Rulemaking, agenda, includes, a future rulemaking, project, to, implement the new criteria for exempting, mortgage escrow requirements at, this. Point however the bureau has not indicated when, it plans to roll out a proposed rule. By. No later than the spring 2019. Agenda, the borough expects. To issue a more comprehensive statement, of its, priorities. Under. The, tred rule with certain, changes to the closing disclosure require. A new three-day waiting period before, consummation. Any. Change. To a loan product, type. Addition. Of a prepayment penalty, though. Not allowed by federal credit unions or, if the APR becomes inaccurate, as defined, by regulation. Section. 109 amends, the Truth in Lending Act and removes, three-day, waiting period required, under the tila-respa integrated, disclosure.
Rule When. A creditor, extends, a second, offer of credit secured. By real property with. A lower annual, percentage rate, this. Provision, applies only to high-cost, mortgage, loans as defied, in Tila. Section. 109 eliminates. The three-day waiting period between, a consumer receiving. A closing, disclosure and, closing, on a loan if the, consumer received, a corrected, closing disclosure that. Includes a lower APR, than, was offered. In the previous disclosure. Note. That the three-day, waiting period is, only the one required, when a corrected, closing disclosure is, issued, this. Does not effect the three-day waiting period for, rescission, otherwise. Required, by Tila. Again. This waiver provision, only applies, to high-cost, mortgage, loans. Now. I will yield the mic to Grace who will discuss specific, consumer protection, amendments and s 21:55. Thank. You well before I proceed I, would, like to remind participants that. If you have a question, you, would like to ask us now please. Submit them in the ask a question box. S. 21:55. Provides, consumers, and veterans, with additional, credit protections. Section. 303, protects. Credit unions, and, certain, credit union employees, from. Liability in, any civil, or administrative, proceeding. In, situations. Where, those employees, make. A report, about the potential, exploitation of, a senior citizen, to, a governmental, agency, so. Long as the credit union has provided training and the, report is made in good faith and with. Reasonable, care. Nothing. In this provision limits, the liability of, an, individual, or a covered, financial, institution. In a, civil action for. Any act omission. Or fraud, that, is not a disclosure, described, in this law. The. Covered credit union employees, include, compliance, and legal personnel. And supervisors. As well, as registered, representatives. Investment. Advisors and, insurance. Producers. Covered. Employees. On our credit union employers. Received immunity from. Civil or administrative proceedings. For the disclosure. Section. 303, also. Provides guidance, regarding, the, content. IMing. And record. Maintenance requirements. Of such training. Title. 6 of, s21. 55 also. Provides additional consumer, protections, related. To student loans. Section. 601, amends. Tila, there. Prohibit, financial, institutions. Including, credit unions, from, accelerating private. Student loan debt solely. On the basis of bankruptcy, or, death of a cosigner. The. Term cosigner, is defined. To mean any individual. Who, is liable for someone, else's obligations, without compensation. Regardless. Of how such individual, is, designated. In the contract, for that obligation, and any. Person. Whose signature, is requested, as a condition, of granting credit or. For, bearing on collection. Please. Note that the following individuals. Are not deemed, co-signers. 1, the. Spouse of an individual, who, is deemed a cosigner, because. He or she is liable for someone, else's obligation. Without, compensation. If the, spouse's, signature.
Is Needed, to perfect, the security, interest in alone and to. An, individual. Who is liable for a private, student loan made. To consolidate. Pre-existing. Student, loans. Section. Xl1 provides, that the holder, of a, private, education loan, must, release a cosigner, from, his or her obligation. Upon, the death of the student obligor and provide. Notification. To the cosigner, within. A reasonable, time of, release. Section. 601, also, requires a lender, provide. A student borrower with, the option. To designate. To. Have the legal authority. With. The option to designate, a person, to have the legal authority to act, on the students behalf with. Respect, to the loan in case of his or her death the. Amendments, applied to private education, loans entered. Into. On. Or, after November 20th. 2018. Section. 602. Amends. The Fair Credit Reporting Act, by. Allowing a consumer, to request that a financial institution. Remove. A reported, default, on a private education, loan from, his or her credit, report if, the. Financial institution. Offers and the. Borrower successfully. Completes a loan. Rehabilitation. Program, designed. By the institution. The. Consumer, may request the removal of a reported, default only, once per loan. Government, accounting office must also in consultation. With the federal banking regulators, induct. And submit a study to Congress, regarding. The costs, associated, with implementing, this, new provision and the, effects of the provision, on the accuracy of credit, reporting. Title. 3 as s 21:55, provides. Specific, credit protections, to veterans and active. Military personnel. Section. 302, amends, vikre, by. Requiring, the, exclusion from, credit reports, of, certain, medical, in a certain. Medical debt incurred by a veteran. Section. 302 defines. Veterans, medical debt as debt. Of a veteran Oh to a health care provider or other. Than this. Other than the Department of Veterans Affairs or, VA and, submitted. To the VA for health care payments, authorized. By the VA it includes. Medical, collection, debt that the VA has wrongfully charged, the veteran. Section. 302, prohibits. The inclusion, of a veteran's, medical debt on credit reports. Were. One year after the provision, of medical services and also, requires that any debt previously. Characterized. As delinquent, charged.
Off Or in, collection, be removed when, the debt has been fully paid or settled. Section. 302 requires. The VA secretary, to. Create a verification, database. To allow CRA, s to. Confirm, whether. That. Furnish, to them is. A veteran's, medical, debt and to verify a, veteran's. Medical debt. Section. 302 also, requires CRA, s to provide free, electronic. Credit, monitoring. Active. Duty members. Of the military, and members. Of the National Guard. Sections. 309. And 313. Provide. Veterans, with protections, against foreclosures. Section. 309, adds, protections. For veterans, who refinance. Their purchase, or construction, home loans. Under. Section, 309 the. VA will not guarantee, or, ensure, the. Refinancing. Of a loan to purchase or construct. A home unless. The insurer provides, a certification, of. The recoupment, period, for expenses, incurred. By the borrower in refinancing. The loan further. All, costs. And fees must, be recouped within 36, months of the loan issuance, and the. Recoupment must, occur through lower monthly, payments. Due, to the refinancing. In. Addition, the, insurer must provide the veteran with, a net tangible. Benefit, test and abide, by certain, rules regarding. The required. Minimum. Reduction, in the interest rate on the refinanced. Loan. Section. 309 also, requires the VA to issue, a report. On cash, out refinances. By May 24th. 2019. Section. 313. Makes, permanent an amendment. To the Servicemembers. Civil Relief, Act that. Allows for a stay of foreclosure, sale. Or seizure, proceedings. For, a service member for, any action, filed during. Or within. One year of the, service members period of service the. Effective, date of section, 313. Was. May 24th, 2018. Title. 3 of S. 21:55. Also, provides consumers, with credit protections. Section. 301 amends, vikre, to. Require CRA, s-21. Allow. Consumers, including. Minors, and, incapacitated. Persons, acting. Through their representatives, the. Place or remove. A security, freeze on their. Credit report, free of charge and to. Notify. Consumers of, their right to a security, freeze. Section. 301 also. Extends, the time for initial, fraud alert from, ninety days to one year further. The, Federal Trade Commission, must, maintain a central. Webpage, linking. Each credit, bureaus webpage, for. You or, requesting. A freeze or. Fraud alert or to, opt out of information, sharing for, marketing purposes, the. Effective, date for section, 301, was. September, 21st. 2018. Section. 603. Requires, the US Treasury Department's. Financial. Literacy and Education, Commission. Solicit. Public comment, and obtain, input from. Relevant parties to establish, best. Practices, for. Institutions. Of higher education. Including. Methods to, teach financial. Literacy. Skills, and to. Ensure that students, are well informed of their total borrowing. Obligations. Within. One year from the date of enactment. These. Practices. Must, include ways to communicate to, students the, importance, of graduating, on their ability to repay, student loans and methods. To ensure that they understand, their borrowing. Obligations. However. Institutions. Of higher education, would. Not be required to adopt, these best practices. S. 21:55. Also, provides, additional, consumer. Protections, because. Of time constraints, we cannot discuss them all but, we list them on this slide, we. Recommend, that you go to s, 21:55, to, review these provisions, the. Next. Two slides list. Under, references. The. Next four slides list some of the references, associated.
With S 21:55. On October, 17. 2018. The bureau's fall 2018. Unified. Agenda was published in it, the, Bureau addresses, which is s, 21:55. S provisions, do, not require Bureau rulemaking. To take effect, for, examples, sections. 101. 104. 106. 107. 301. And, 601. Even. Though Bureau rulemaking. Is not required, for these provisions. To take effect Bureau, has noted, in a unified, agenda that, notice and comment rulemaking may. Be helpful to better implement or clarify, these provisions. Unified. Agenda also. Notes those. Provisions, in s, 21:55. Requiring, Bureau, rulemaking. In. Today's. Webinar we, discussed the changes made to HMDA, in regulation, C data collection, and reporting requirements. Made. By the dodd-frank act, and. The bureau as well, as the recent changes to HMDA and regulation, C regarding. Exemptions, allowed for collection, and reporting a certain data points, we. Also discussed. The 2018, changes. The, various consumer, financial protection, laws from, s 21:55. Again. If you have any questions, you would like to ask us now please submit them and ask a question box if, you. Have questions, you want to submit to us after, the webinar please. Feel free to email us at the address provided, on this slide. It's. Now time to answer some of your questions. We'll. First go. Questions we received, prior, to today's broadcast, and. We. One question about member, business loans and specifically. I heard. That s 21:55. Made, a change to member, business, loans is that right, I'll. Answer, this question, and yes. Section. 105. Of s 21:55. Excludes. From the statutory, definition. Of member, business loan an extension. Of credit fully, secured, by lien on a, 1, to 4 family dwelling that is not the primary residence. Of a member this. Means that loans for those properties, not. Count against the cap imposed, on each federally, insured credit, union. By, the FCU. Act previously. Only, loans secured, by 1 to 4 family dwelling, that is the, members primary, residence, were excluded, this. Change was reflected, in the NCUA's, rules and regulation, through, a notation. Vote on May 30th, 2018. We. Also received, a, couple. Of questions about. NCUA's. 2018. And, 2019. Hundred. Reviews and. I'll ask Matt to answer both of these questions so the first question. Last. Year, NCUA, issued, guidance on the new SSI. See uniform. Under resubmission. Guidelines, which. You did not discuss, in today's webinar, are these. Exempt, EU examiner's, using, these procedures, for the 2018 hundred, reviews you are performing. Thanks. Grace, yeah. NCUA. Did, issue a. Letter, to credit unions in. August. 2017. I believe, it's letter 17, cuo 4, which. Addresses, hungary, submission. Guidelines, that. We. At NCUA, and, our, sister. Agencies, so that would be the. FRB, OCC. FDIC. And, B. CFP. We'll. Use, when, we test HMDA, accuracy. In the. Regular in our, regulated. Institutions. We, are not using these formal, testing, procedures, or the, HMDA reviews, that. We are completing. This year, which, are the, ones that we discussed, in today's webinar. The. Procedures. Discussed. In letter, 17. Cuo 4. Require. Correction, and resubmission, of a credit unions HMDA lar when. NCUA. Examiner's. Following. Formal, testing, procedures. Observe. Error rates, that, exceed, specified. Thresholds. The. Reviews. Discussed, in today's webinar, are. Informal. HMDA reviews in other words. They're. Not using. Statistical. Sampling, tables, and. The. Reviews. This year are intended. To provide. Credit unions, with constructive. Feedback. Before. They file their, 2018. HMDA, lars in. 2019. However. We do encourage, credit, unions, to. Familiarize, themselves, with, the letter since. The procedures, discussed. Could, result, in NCUA. Requiring. A credit union the. Correct, and resubmitted, somedll are. Normally. During a fair lending examination. The. Procedures. Discussed. In that letter are not. Widely, used outside, of our fair lending examination, program. Thanks. Matt the. Other question, had to do. With, whether. NCUA. Examiner's. Are performing. Hunza reviews. In. 2019. We. Are currently in, the process of, finalizing. 2019. Examination. Priorities. Honda. Will likely be, included. But. I can't, say more at this, time until, we, actually. Finalized. The, the, program. Definitive. All of the, all. Of the issues contained, within. Thanks.
Again That um al. We got a, couple of questions about QMS. The. First question, is, if. A credit, union meets, all of the section, 101, provisions. For QM relief what. Is a credit, union need, to do to determine ability. To repay in order, to reduce potential, liability. Okay. So, under the change and we're talking about section 101 of. S21, 55. The. Credit union must consider the borrower's debts income. And, other financial resources if you, recall back, in, 2013. The bureau, issued. The, ability, to repay or ATR rule and this, is this rule implemented, the dodd-frank act requirement, of. Looking. At the borrower's ability, to repay the, loan, so. Accredit Emma still verify. Well. Under that rule the credit you must verify and document, that at the time of the mortgage when, it's made at the time it's made the, borrower has the ability to repay the loan so. A credit union then, can comply with the ATR requirement. By originating, a qualified, mortgage, or QM. Section. 101, merely. Creates, a new safe harbor, category. Of QM, loans but. Allowing multiple. Or multiple, methods of documenting, the Barros ATR, though. The ability-to-repay, is still a requirement, so, therefore, all QM, loans are, presumed, to have complied, with the ATR, requirement, thereby. Reducing, the credit unions potential, legal liability, or. Its residential, mortgage lending activities. Thank. You L and the, next question, asks. Our. Credit, union has, 8 billion, in assets and, we, are in the process of requiring it banks. Residential. Mortgage portfolio, through, a business, combination in, those, loans be treated as QMS. If. The banks, Sloane's meet, the section 101 conditions for, QM relief, as we discussed, in the presentation. The. Safe harbor remains, available, to the acquiring, credit union when. Legal title to a residential, mortgage loan, is transferred, as a result. Of a merger. To. Apply the safe harbor however such. Loans must be held in portfolio of. The acquiring credit union. Thanks. Again Al and. Matt. I have another HMDA. Question for you that, not only was, provided. To us prior, to the webcast but we also have a number, of credit, unions asking, the, same questions, through the ask a question box, and, it. Basically they're. Basically, asking is. The. Current HMDA volume threshold for, open-end lines of credit 500. Annalee, and will. This change to 100, annually, in 2020. Yes. Currently, both, the, volume threshold for. Reporting, opened, in lines of credit, and the, partial exemption. Volume, threshold is. 500. Opened, in lines of credit, in each, of the two preceding calendar, years. The. 2015. HMDA. Final, rule, set. The institutional. Coverage, volume, threshold at. 100. Opened, in lines of credit, but. In. 2017. The. Bureau finalized. A rule that, temporarily. Increased. The, openden threshold, to. 500. For calendar, years, 2018. And, 2019. In. Doing, so the. Bureau indicated. That the 2-year period would. Allow time for the bureau to decide. Through. An additional, rulemaking, whether. Any permanent, adjustments. To the open den threshold, are needed. So. It, is possible. That. Before. 2020. The, bureau will, make permanent, the, temporary. Volume. Threshold, five hundred or. They. Could make permanent a different, threshold, but. With, no further action from, the bureau, the, institutional. Coverage, volume, threshold, will. Revert, to, 100. In 2020. Thank. You Matt and. Some. Of the questions that have been submitted. To, be asked a question, box. Involved. Hum dose so I'll be asking Matt to answer a few of these, the. First question, asked. So. Until. Our financial, institution. Completes. 30 mortgages. In the prior two years we. No longer have, to file under regardless. Of asset size, for. Example if, we fund 35, mortgages, this year and next we. Filed HMDA, in 2021. The. The. Institutional. Coverage. Criteria. Or. Closed. In mortgage, loans is is. Set at 25. So. If. A. Credit. Union. Originates. 25. Closed. In mortgage, loans in. Each. Of the two preceding. Calendar years, and. They. Meet the other. Coverage. Criteria, such. As having a, home. Or, branch office, in an MSA, and, having. Total assets, of at least 45, million. Then. They, are still required to. File. A hum to report and. One. Thing that's somewhat, confusing. With, the discussion. That, we've introduced, with, the partial, exemptions. Is. What. We talked about with the partial, exemptions, that. That's. Separate. From whether, a credit. Union has. To complete. A honda, report whether. Our credit union has to complete. A honda report would. Be determined based, on the institutional. Coverage, criteria, whether. A credit union is, exempt.
From. Reporting. The 26. Data. Points, that we talked about today. That's. Defined, by the via. Threshold. The. 500. Or more in the prior two calendar, years threshold. For both, closed-in. Mortgages, and opening. Lines of credit. Thank. You Matt speaking. About the, 26. Data points, we. Have another question asking, if. We. Are personally, if we are partially, exempt for Honda are we, allowed to not, report, the 26, data points, for, all of 2018. Yes. That that is correct, so the. S. 21:55. Was. Passed. During. The middle of the year or actually, it, was passed in the in the latter half of this year, but. It. Applies. It. Applies to the entire calendar. Year so if. If, a credit union. Qualifies. For a partial, exemption, then. That partial, exemption, applies. To. All. Loans. And applications. Where. Action, was taken, in, 2018. Not. Just, those that, occurred. After. Implementation. Of, the wall. Thank. You Matt. Another. Question, has, to do with, filing. Orderly, law and so, the question asks I may. Have misunderstood. But, did the speakers say that financial, institutions. Are, to file our information. Quarterly. No. There. There is an annual, filing. Require. What. The regulation. Requires. Is. That. Large. Information. That occur occurred, during, a particular. Calendar, quarter, must. Be. Recorded. On, a lar. Within. 30, days after a quarter, in so. In. Effect, a. Credit. Union is required, to, be updating. Their lar, quarterly. Even. Though they, only file, once. Per year. Thank. You Matt I think we have time for one more question. It. Deals with MSAs, and the, question, asks our credit, union has a branch, in an MSA. That. We do not qualify, for any exemptions. Correct. Yes. So again. We, we have to make a distinction, between. Institutional. Coverage, and. Qualifying. For a partial, exemption. The. The two are separate, and they. Have different coverage. Criteria. The. Whether. A credit union as a. Branch or home off is located. In an MSA. Is. Part, of the criteria to. Determine, whether, or not, a. Credit. Union has to file, a HMDA. Lar. It's. It's, separate. From whether, they qualify for an, exemption, so. If. A credit, union has a branch, in an MSA.
Has. No, bearing, on whether. Or not they, qualify, for an, exemption. Thank. You very much Matt and. Again. If you have any questions. You would like to ask our office, please. Feel free to email, us at, the address. Listed, on slide 57. Thank, you Joe mad canal, and thank. You everyone, for attending today's, webinar we'll. Talk to you credit unions again soon goodbye.
2019-01-06 14:48
