Small Bank HMDA Exemptions
Bank industry lobbyists were successful in persuading Congress that the current size exemption from HMDA reporting is unnecessarily low. Although Congress did not enact a new exemption level, it adopted a formula for the FRB to apply and adjust the exemption level for small banks.
The FRB will now adjust the EWA annually after December 31, 1996 by the amount of the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers. This index is published by the Bureau of Labor Statistics.
In addition to this future regular price adjustment, the FRB will make a one-time adjustment based on the change in this index for the time period between 1975 and 1996. This adjusts the original exemption level for HMDA for inflation since HMDA was enacted.
Copyright © 1996 Compliance Action. Originally appeared in Compliance Action, Vol. 1, No. 16, 10/96
First published on 10/01/1996