One might think that using the HMDA partial exemption for small filers would make life easier. Much easier. Well, for the most part, that is true. The CFPB’s interpretive and procedural rule provides relief for certain “small HMDA filer” so that they are exempt from reporting about half of the data fields (22 out of 48 total data fields). The problem with the HMDA partial exemption, however, is that the rules to comply with the partial exemption are actually quite confusing. For example, the CFPB interpretive and procedural rule provides a number of different ways to report exempt data fields, and even creates some confusion on one particular data field: the State data field.
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