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Modifications and HMDA

Question: 
We sometimes originate dwelling secured transactions via modifications that work just like New York CEMAs, that will be reportable for HMDA beginning in 2018, but the property is not in New York. Should we report it when everything else about the transaction is the same?
Answer: 

No. The only modifications that will be reportable will be the New York CEMAs. The CFPB has said that they understand that there are some other geographic regions with similar transactions but that those are not to be reported at this time. The CFPB will monitor those other programs and make future determinations if any of those will become reportable.
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Learn more about Kathleen Blanchard’s webinar Complex challenges in the new HMDA rules

First published on 07/10/2016

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