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#2114060 - 01/12/17 06:25 PM New Rule Clarification
Compliance Lover Offline
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Joined: Aug 2008
Posts: 555
If we had less than 25 loans in 2015 and 2016 then I believe we would be exempt for 2017 loans. But, I still report for 2016 correct?
Then in 2017, we wouldn't need to gather gov't monitoring information?

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#2114063 - 01/12/17 06:39 PM Re: New Rule Clarification Compliance Lover
solbrillante Offline
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solbrillante
Joined: May 2011
Posts: 85
That was my understanding.

We had less than 25 in 2015, so even we had 25 or more in 2016 it doesn't matter. We are not collecting and reporting for 2017 because we don't meet the institutional coverage for both 2015 and 2016.

However, yes, you still have to do the submission for 2016 if you were subject to HMDA in 2016.

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#2114075 - 01/12/17 07:37 PM Re: New Rule Clarification solbrillante
Compliance Lover Offline
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Posts: 555
Thank you!

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#2114535 - 01/18/17 02:55 PM Re: New Rule Clarification Compliance Lover
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Yes, the new coverage test goes into effect 1/1/2017 and only affects your collection and reporting of transactions with action dates in 2017. If you met the rules for 2016, you will submit your 2016 data.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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