Hopefully, by now, you’ve determined whether your financial institution will be subject to the Section 1071 data collection and reporting requirements. If not, that’s your first priority. If you will be subject to Section 1071, you are likely aware that it applies to non-consumer credit applications where the applicant’s gross annual revenues are less than or equal to $5 million (aka a small business) and that are “1071-reportable” under the Rule. Keep in mind there are several exclusions to being 1071-reportable. One of those exclusions is for HMDA-applicable transactions. In other words, applications subject to HMDA are not reportable for Section 1071.
This HMDA exclusion applies regardless of whether your financial institution is subject to HMDA or not. So, if you are not a HMDA reporter, you actually have more to learn.
Jerod explains more in the video.
Video Highlights:
- HMDA-reportable applications are not to be reported for Section 1071.
- Institutions subject to HMDA will likely have an easier time understanding what’s reportable for Section 1071, but there will still be a learning curve.
- Institutions not subject to HMDA must understand what applications are HMDA-reportable to ensure Section 1071 reporting is accurate.
Published
2023/12/08
