NCUA Reg Alert Reviewing Reg C Requirements on HMDA Data

ALEXANDRIA, Va. – The NCUA last week issued Regulatory Alert No. 05-RA-01 targeted at credit unions involved with residential mortgage lending to review requirements for filing 2004 HMDA data with the board of the Federal Reserve System by the March 1st deadline. Specifically the regulatory alert addressed: * the 2005 reporting threshold for HMDA – the Federal Reserve Board announced the exemption threshold for depository institutions required to report data under HMDA increased to $34 million in assets effective Jan. 1, 2005. An exemption from filing HMDA data for the 2005 calendar year doesn’t affect the requirement to collect and file 2004 data; * reference material, such as the HMDA Guide to Getting it Right – the most recent version of this guide was published in December 2003; * the availability of reporting software for the 2005 calendar year data- for those CUs required to collect HMDA data during the 2005 calendar year; * reporting options for credit union service organizations – CUSOs must comply with HMDA data collection and reporting requirements; * filing deadline for 2004 HMDA data – HMDA requires quarterly updates of the loan application register (LAR). Once final action is taken on a transaction, it must be appropriately recorded on a LAR within 30 days after the end of a calendar quarter; * NCUA policy concerning the late submission of required HMDA data- CUs must provide a readable file to the FRB by the March 1st deadline. NCUA may assess civil money penalties against late filers; * potential errors during the collection and report of 2004 data – NCUA recommends CUs review a guidance letter issued in December 2004 by the Federal Financial Institutions Examination Council that was mailed to anticipated 2004 HMDA filers. The letter covers unique transition rules for select 2004 data.