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#2242135 - 09/08/20 06:52 PM Partial Exemption
COMPL101TX Online
100 Club
Joined: Apr 2018
Posts: 108
For counting the number of closed-end mortgage loans originated during the prior two calendar years, I understand you would remove home improvement loans not secured by a dwelling from the count and loans exempt under section 1003.(c)(1) through (10) or (13).

Would I need to add any loans that would be reported with the new rules but not under the old rules? Would there be any?

This is my first year at a HMDA reportable bank...I understand the new rules but lack some knowledge of the old rules.

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#2244530 - 10/23/20 02:54 PM Re: Partial Exemption COMPL101TX
Compliance NABW Offline
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Joined: Oct 2015
Posts: 1,669
Yes, the count for threshold purposes is based on the "new rules," but only includes "originations" of credit. However, if you are making the determination now or going forward, then you really shouldn't have to worry about the old rules because both preceding calendar years, i.e. 2018 and 2019, and anything thereafter would encompass data collection criteria for the "new" HMDA. But, yes, there are a few types of loans that would have to be counted under the new rules that would not have been counted under the old rules. The biggest category would be "Other," such as taking out a loan on a previously "free and clear" dwelling and using the funds for debt consolidation.

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