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BankersOnline.com Forums Dodd-Frank Final Rules Discussions HMDA Overhaul 2018 no longer HMDA filer
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#2129488 - 05/05/17 08:23 PM no longer HMDA filer
Chocaholic Offline
Gold Star
Joined: Aug 2005
Posts: 443
Northwest
We have determined we no longer meet the over 25 threshold nor at this time the HELOC threshold... so my question, we no longer need to collect gov't monitoring information correct? I realize we still need to collect fair housing information so should be continue HMDA data for 2017 although not report and discontinue in 2018?
Confused

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#2129519 - 05/07/17 12:17 PM Re: no longer HMDA filer Chocaholic
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
You still have to collect GMI under Regulation B for loans covered under 1002.13.
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#2129525 - 05/08/17 12:47 PM Re: no longer HMDA filer Chocaholic
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,533
Bloomington, IN
So you are saying as of December 31, 2016 you no longer met the requirements to collect data in 2017?
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2129789 - 05/09/17 09:48 PM Re: no longer HMDA filer Dan Persfull
Chocaholic Offline
Gold Star
Joined: Aug 2005
Posts: 443
Northwest
yes, that is correct.

I understand Reg. B has some requirements to collect on dwellings that are principal residences and some requirements under FHA as well.

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