September 1, 2014

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Home Mortgage Disclosure Act's Regulation C Exemption Limits Increased by Consumer Financial Protection Bureau "CFPB"

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.

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About this Author

Jeffrey M. Werthan, Mergers Acquisitions Attorney, Katten Muchin law firm
Partner

Jeffrey M. Werthan is head of the firm’s Banking practice. He has extensive experience representing clients in connection with bank formations, both public and private capital raises, mergers and acquisitions of financial institutions, compensation for financial institution executives and bank regulatory and enforcement issues.

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