On Friday, the Bureau of Consumer Financial Protection issued a clarification of changes to HMDA for credit unions and small banks.  This was mandated in the Dodd-Frank reform bill from earlier this year.

That legislation granted partial exemptions under HMDA.  The bulletin states that “only loans and lines of credit that are otherwise HMDA reportable count toward the thresholds for the partial exemptions.

“At a later date, the Bureau anticipates that it will initiate a notice-and-comment rulemaking to incorporate these interpretations and procedures into Regulation C and further implement” the law.