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  2. Partial Exemption

Partial Exemption

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View answers to questions regarding the HMDA partial exemption. Simply click on a question below to see the answer.

  • Does the partial exemption mean credit unions are exempt from filing?
  • If you qualify for exempt reporting, are you still required to report the state of the property?
  • If we originated less than 500 loans in the past two years for closed-end, are we exempt from reporting HMDA?
  • Does an exempt credit union need to use an LEI?
  • Where can I view a chart of data points for exempt institutions?
  • Clarifying the partial exemption, would we be exempt if we "originate" fewer than 500 closed-end in BOTH 2017 & 2018? That would also apply to open-end, if less than 500 were "originated".
  • We originate more than 500 closed end mortgages, but we don't originate more than 500 open ended lines. I just want to verify, we are partially exempt only for open ended lines? And we can report the reduced data for open-end lines only?
  • If we are not required to report open-end lines of credit (we didn't close more than 500 originations in the last two years), do we have to include the actual loan on the LAR and then use the Exempt fields?
  • Can you clarify whether an exempt credit union will need to use an LEI, as we did last year. The info I see, read and researched seems to indicate that we can drop the LEI and simply use loan number this year - despite having used the LEI last year?
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