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.

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