By, Gina Ellis
The asset threshold for determining applicability for Home Mortgage Disclosure Act (HMDA) reporting for 2016 remains unchanged at $44 million. Any financial institution located in a Metropolitan Statistical Area (MSA) with total assets of $44 million as of December 31, 2015 will be subject to HMDA data collection and reporting in 2016. However, there is a change for financial institutions located in Oklahoma with the addition of a new MSA in Enid, Oklahoma consisting of Garfield County. Financial institutions in this new MSA that meet the total asset threshold should begin collecting HMDA data for applicable applications received January 1, 2016.
The Community Reinvestment Act (CRA) asset thresholds for determining classification as a small bank, intermediate small bank or large bank evaluation have decreased slightly for 2016. A small bank or small savings association is defined as having total assets less than $1.216 billion in either of the prior two calendar years. An intermediate small bank or savings association is defined as having total assets of at least $304 million for both of the prior two calendar years but less than $1.216 billion for either of those same years. A large bank or savings association is one having total assets of $1.216 billion or more for both of the prior two calendar years. These thresholds will determine the evaluation examination procedures performed by each of the regulatory agencies.
The asset threshold for determining small creditor status under Regulation Z is also lower for 2016 at $2.052 billion. This threshold determines whether the ability to repay qualified mortgage and higher priced mortgage loan (HPML) escrow rules apply. Other points and fee thresholds used for determining whether a loan is a High Cost Mortgage (HCM) or for determining Qualified Mortgage (QM) have also decreased. The thresholds for determining coverage under HPML appraisal requirements as well as Truth in Lending and Consumer Leasing regulations remain unchanged from 2015 levels at $25,500 or less and $54,600, respectively.
At ABS, we are here for you. Please contact one of our consulting experts at 800.522.4990 if you have questions about these new thresholds and the applicability to your financial institution.