CUNA News
  • LOG IN
  • Create Account
  • Sign Out
  • My Account
  • LOG IN
  • Create Account
  • Sign Out
  • My Account
  • Credit Union Magazine
    • Buyers' Guide
    • Digital Edition
    • Credit Union Hero
    • Credit Union Rock Star
    • Subscribe
    • Advertise
    • Contact
  • Advertise
  • Topics
    • Community Service
    • Compliance
    • Credit Union Hero
    • Credit Union Rock Star
    • Credit Union System
    • Directors
    • Human Resources
    • Leadership
    • Lending
    • Marketing
    • Operations
    • Policy & Issues
    • Sales & Service
    • Technology
  • Awards
    • Nominate Credit Union Hero
    • Nominate Credit Union Rock Star
  • Podcasts
  • Videos
  • Jobs
  • Contact

News

Home » Agency clarifies S. 2155 HMDA changes

Agency clarifies S. 2155 HMDA changes

Act provides an exemption from the collection of certain data points.

November 28, 2018
Whitney Nicholas
No Comments
Agency clarifies S. 2155 HMDA changes

Data collection

When S. 2155 passed in May and promised a partial exemption from the collection of certain data, everyone was left to wonder which data points would be covered by the partial exemption and which would still be required to be reported.

The bureau addressed this in the Aug. 30, 2018, rule and provided a list of the 26 data points eligible for the exemption and the remaining 22 data points that are still required for all HMDA reporters.

Credit unions that do not meet the 500-loan threshold and qualify for the partial exemption will report fewer data points than those that do not qualify for the exemption.

Voluntary reporting

The rule also states that optional voluntary reporting of the expanded data points covered by the partial exemption is permissible, provided that the credit union will submit data for an entire data point when data are reported for any data field within that data point.

This will ease the compliance burden for institutions whose loan volume thresholds may fluctuate from year to year.

While it may be easier from a compliance standpoint to continue to report data in a given year even if your credit union qualifies for the exemption, keep in mind that you can still be held accountable for any discrepancies in the data that you report.

Universal Loan Identifier

The last big change in this rule pertains to the Universal Loan Identifier (ULI). Insured credit unions are not required to report a ULI for loans that are partially exempt (although the rule states that credit unions may still voluntarily report the ULI if they prefer).

But credit unions that qualify for the partial exemption must still provide information so each loan and application they report is identifiable for HMDA purposes. This allows the credit union to report the loan identifier without requiring it to obtain the Legal Entity Identifier (LEI) as part of the ULI if the credit union qualifies for the partial exemption.

As a result, the August 2018 final rule has amended the ULI requirement to only require a “non-universal loan identifier” that doesn’t have to be unique within the industry. That means it doesn’t have to contain an LEI.

However, the non-universal loan identifier does have its own requirements. For any partially exempt loan or application for which the credit union does not report a ULI, the non-universal loan identifier:

  • *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 information that could be used to correctly identify the applicant or borrower.

“The year of HMDA”—as 2018 is known—has been big for credit union compliance. As the year comes to a close, hopefully credit unions can rest a bit easier knowing we finally have some clarity with respect to the new HMDA changes.

HMDA appears to be the ever-evolving rule, and this doesn’t appear to be changing any time soon.

BCFP has stated it intends to re-open the rule for further examination again in 2019. We hope this will lead to more positive changes for credit unions in the form of less regulatory burden.

WHITNEY NICHOLAS is senior federal compliance counsel for CUNA. Contact her at 202-508-6702.

Previous 1 2 Next
KEYWORDS advocacy

Post a comment to this article

Report Abusive Comment

Credit Union Magazine: Rock Stars 2023

Rock Stars 2023

Credit Union Rock Stars are outstanding credit union professionals and directors from a wide range of disciplines who inspire and innovate to advance the missions of their credit unions. The 25 members of the 11th class of Rock Stars were selected for their exceptional creativity, innovation, and passion.
Digital Edition •  Subscribe

Trending

  • Meet the 2023 Credit Union Rock Stars

  • Senate Banking Committee passes cannabis banking bill

  • Senate committee to mark up SAFER Banking Act this week

Polls

Do you plan to use the FedNow instant payment service?

View Results
More

Champion for the Credit Union Movement

Credit Union National Association is the most influential financial services trade association and the only national association that advocates on behalf of all of America's credit unions. We work tirelessly to protect your best interests in Washington and all 50 states. We fuel your professional growth at every level and champion the credit union story at every turn.

More CUNA

  • Membership
  • Contact Us
  • Careers

Resources for

  • Credit Union Advocates
  • Leagues
  • Press
  • Providers

Our Affiliates

  • American Association of Credit Union Leagues (AACUL)
  • Credit Union Awareness
  • Credit Union House
  • CUNA Strategic Services
  • National Credit Union Foundation
GET CUNA UPDATES
© 2023 Credit Union National Association | ADA Compliance Notice & Legal
Email Us