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The Consumer Financial Protection Bureau (CFPB) on December 28 issued a final rule adjusting the asset-size exemption threshold for banks, savings associations and credit unions under Regulation C, which implements the Home Mortgage Disclosure Act (HMDA).
Based on the adjustments announced, the asset-size exemption for banks, savings associations and credit unions will increase to $42 million. As a result, those institutions with assets of $42 million or less as of December 31, 2012, are exempt from collecting HMDA data in 2013. An institution’s exemption from collecting data in 2013 does not affect its responsibility to report the data it may have been required to collect in 2012.
©2013 Katten Muchin Rosenman LLP