Skip to content
BOL Conferences
Learn More - Click Here!

Thread Options
#1923242 - 05/14/14 07:04 PM CEMA and HMDA Reporting
LillyNY Offline
Junior Member
Joined: Aug 2012
Posts: 48
Central NY
We've always reported on our HMDA LAR any new money used for a HMDA reportable purpose (such as home improvement) when doing a NY CEMA. I've recently heard that it is now the FFIEC's position that CEMAs are not HMDA reportable at all even if new money is being advanced but have been unable to find anything in writing on the subject. Has anyone heard or seen anything on this subject?

Return to Top
#1924395 - 05/19/14 04:45 PM Re: CEMA and HMDA Reporting LillyNY
Reads Regs Offline
Diamond Poster
Joined: Nov 2004
Posts: 2,310
The FFIEC HMDA Web site has FAQs RE: HMDA. See this one on MECAs.

http://www.ffiec.gov/hmda/faqreg.htm#meca
_________________________
Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.

Return to Top
#1924975 - 05/20/14 08:37 PM Re: CEMA and HMDA Reporting LillyNY
LillyNY Offline
Junior Member
Joined: Aug 2012
Posts: 48
Central NY
Thank you. I'm familiar with that FAQ and it is the reason that we do not report on our LAR the CEMA itself or the existing mortgage that is not being extinguished. We do however, report the new mortgage (or new money) if the proceeds are being used for a HMDA reportable purpose such as home improvement. It's the new mortgage (that is subsequently combined with the existing mortgage by the CEMA) that I have heard the FFIEC is saying is no longer reportable. Has anyone seen any guidance on this?

Return to Top
#1924978 - 05/20/14 08:38 PM Re: CEMA and HMDA Reporting LillyNY
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
When I was in banking in NY, we did not report mods, new money or not, regardless of purpose.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#1925011 - 05/20/14 09:24 PM Re: CEMA and HMDA Reporting LillyNY
LillyNY Offline
Junior Member
Joined: Aug 2012
Posts: 48
Central NY
Interesting. Thank you.

Return to Top
#1925049 - 05/21/14 01:58 AM Re: CEMA and HMDA Reporting LillyNY
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Two things.

A few years ago, the FRB stated that a mod of a construction to a permanent loan was reportable as a purchase.

Second, for CRA, modifications that extend the maturity date and/or add new money are reportable.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top