Bank Regulation AlertHMDA Changes Force Update of CRA Public File Requirements
2/27/2018 - By Janet Munns, CRCM
Effective January 1, 2018 - The Community Reinvestment Act (CRA) was amended on November 20, 2017 by the Federal Deposit Insurance Corporation, the Federal Reserve and the Office of the Comptroller of the Currency. The joint agency final rule revises the definitions of “home mortgage loan” and “consumer loan” to more closely align to the new revisions of the Home Mortgage Disclosure Act (HMDA). Both the HMDA and CRA revisions became effective January 1, 2018.
The CRA amendment also modifies the CRA public file content requirements. Institutions that are required to report HMDA data, whose disclosure statements for the prior two years are available on the Consumer Financial Protection Bureau’s (CFPB) website, are no longer required to maintain copies in their public file. However, institutions must maintain the HMDA disclosure statements in the institution’s public file if the information is not available on the CFPB’s website.
Additionally, the amended rule contains technical corrections and removes obsolete references to the Neighborhood Stabilization Program.
About the Author | Janet Munns, CRCM
Janet is a consultant in the Financial Institutions Advisory Group at Saltmarsh, Cleaveland & Gund and has been serving the financial institutions industry since 1982, focusing on compliance, operations, policies and procedures. Janet is primarily involved in performing fair lending, loan internal audit, loan compliance, and other consulting services for our financial institution clients.
Related Posts
- Advisory Insights: Introducing the New Lease Standard
- Bad Examples Make Good Lessons
- HMDA Data Collection FAQ: Should You Start, Stop, or Continue?
- CFPB Issues New Rule: A Light in the TRID Black Hole
- The Bank Advisors Host Their First CFO Roundtables of 2018
- Don't Fall Victim to Cyber Crime!
- Your Financial Institution's Role in the Fight Against Human Trafficking
- Advisory Insights: Financial Institutions - Options for Syndicated Loans
- Leadership in Your Community
- What's New? CFPB Releases New Five Year Strategic Plan
- Bank Regulation Alert
- No More Free Lunches... Or Rounds of Golf!
- Branch Operations: Dual Control vs. Dual Presence
- 2018 HMDA FAQ: CRA Public File and Branch Disclosures
- CFPB Announcement: New Asset Size Thresholds
- Regulatory Update: Servicemember Lending
- Avoid Fair Lending Risk! Track Pricing Exceptions
- Storytelling Matters: Sharing Your CRA Efforts During Exams
- 2018 HMDA Prep: Sample Sizes & Error Thresholds for Examiner Testing
- Effective Now: New Third-Party Sender Registration Rule
- 2018 HMDA Prep: Examiner Guidelines for Testing HMDA Data
- Conference Prep: Don't Forget Networking Opportunities
- How to Help Your Customers Impacted by Hurricane Irma
- Regulatory Tripwire! Home Equity Line of Credit Statement Format
- Identifying Third-Party Sender Relationships
- View All Articles
Who We Are
Our professionals have the depth of experience, industry knowledge and worldwide resources to help you reach your goals. We put your success above all else as your trusted advisor.
What We Do
Saltmarsh offers a full range of professional services to accommodate your needs – from tax planning and accounting services to information technology and employee benefits consulting.
Who We Serve
Saltmarsh serves individuals and businesses. Personal attention, access to the right professionals and rapid response is how we serve.
Contact Us
FORT WALTON BEACH
(850) 243-6713
ORLANDO
(407) 203-8990
ST. PETERSBURG
(727) 821-9200
NASHVILLE
(615) 661-0885
PENSACOLA
(850) 435-8300
TAMPA
(813) 287-1111
info@saltmarshcpa.com
(800) 477-7458
