Study guide
10.2 HMDA Exclusions, Partial Exemptions and Data Points
CRCM Certified Regulatory Compliance Manager Exam
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1 1. CRCM Exam and Study Planning
1.1 CRCM examination, eligibility and study strategy
2 2. Electronic Transfers and Error Intake
2.1 Regulation E: Coverage and Consumer Disclosures 2.2 Regulation E: Error Notices and Unauthorized Transfer Liability 2.3 EFT Error Investigation and Provisional Credit
3 3. EFT Investigations, Remittances and Prepaid Accounts
3.1 Extended Error Rules and Remittance Transfers 3.2 Prepaid accounts and special Regulation E controls 3.3 Truth in Savings: Account Disclosures and APY
4 4. Overdraft Operations and Advertising
4.1 Overdraft Practices, Fees and Advertised Terms
5 5. ECOA Applications and Credit Decisions
5.1 ECOA Coverage, Protected Bases and Application Inquiries 5.2 Age, Spousal Signatures and Joint Credit Intent 5.3 ECOA Action Notices and Specific Reasons
6 6. Valuations and Fair Lending
6.1 Business Credit Notices and Appraisal Delivery 6.2 Fair Lending: Treatment, Effects and Comparative Evidence 6.3 Redlining, Steering and Qualified Self-Tests
7 7. Credit Cards, HELOCs and Open-End Credit
7.1 Credit Cards: Coverage, Disclosures and Ability to Pay 7.2 Credit Card Fees, Payment Allocation and Billing Errors 7.3 HELOCs and general open-end credit
8 8. Closed-End Credit and Mortgage Disclosures
8.1 Closed-End Credit: Disclosures, Finance Charges and APR 8.2 Rescission Timing and Ability-to-Repay Standards 8.3 TRID Integrated Disclosures: Loan Estimate, Closing Disclosure & Fee Tolerances
9 9. Education Loans and Mortgage Insurance
9.1 Private education loan disclosures and cancellation 9.2 Homeowners Protection Act and PMI termination
10 10. HMDA Coverage and Reporting
10.1 HMDA Institutional and Loan Coverage 10.2 HMDA Exclusions, Partial Exemptions and Data Points 10.3 HMDA: Loan Application Register (LAR) Compilation, Demographic Collection & Submission
11 11. Flood Insurance
11.1 Flood Determinations, Notices and Required Coverage 11.2 Flood Contents, Escrow, Private Policies and Force Placement
12 12. CRA Evaluation and Assessment Areas
12.1 CRA Institution Categories and Performance Tests 12.2 Community Development, Ratings and Performance Context 12.3 CRA Assessment Areas and Public File Contents
13 13. CRA Disclosures, Branching and Consumer Protection
13.1 CRA File Deadlines, Notices and Sunshine Agreements 13.2 Interstate banking and branch closing duties 13.3 Unfairness, Deception and Consumer Injury
14 14. UDAAP Controls and Social Media
14.1 Abusiveness and UDAAP Program Controls 14.2 Social media advertising, complaints and records
15 15. BSA Programs, Customers and Currency
15.1 BSA Program Pillars and Independent Testing 15.2 Beneficial Ownership, CIP and Ongoing Due Diligence 15.3 Currency Reports, Aggregation and Exemptions
16 16. Suspicious Activity and Sanctions
16.1 Suspicious Activity Reporting, Confidentiality and Records 16.2 Sanctions Scope, Ownership and Blocking Decisions 16.3 OFAC Reports, Records, Licensing and Screening Controls
17 17. Check Availability and Exception Holds
17.1 Regulation CC Scope, Deposit Days and Next-Day Items 17.2 Initial-Dollar Availability, Ordinary Checks and Policy Disclosures 17.3 Exception Hold Grounds and Reasonable Periods
18 18. Hold Notices and Settlement Services
18.1 Hold Notices, Timing and Consumer Communications 18.2 RESPA Coverage, Referral Payments and Fee Splits 18.3 Permissible Services, Ownership Returns and Marketing Agreements
19 19. Mortgage Servicing
19.1 Escrow, Servicing Errors and Force-Placed Insurance 19.2 Early Intervention, Continuity of Contact and Loss Mitigation
20 20. Consumer Reports and Credit Decisions
20.1 Consumer Reports: Permissible Purpose and Employment Use 20.2 FCRA Adverse Action Notices and Credit Score Disclosures 20.3 Risk-Based Pricing and Furnisher Accuracy Duties
21 21. Furnishing, Medical Information and Identity Theft
21.1 Negative Information Notices and Furnisher Disputes 21.2 Medical information in credit decisions: Regulation FF and V 21.3 Identity Theft Program Scope, Governance and Detection
22 22. Identity Theft and Debt Collection
22.1 Red Flag Responses, Program Updates and Address Validation 22.2 Debt Collector Scope, Calls and Communication Limits 22.3 Electronic Collection Messages and Validation Disputes
23 23. SCRA Protections and MLA Coverage
23.1 SCRA Eligibility and the Six-Percent Interest Cap 23.2 SCRA Foreclosure, Repossession, Leases and Waivers 23.3 MLA Borrowers, Identification and Credit Exemptions
24 24. Military Credit and Consumer Communications
24.1 MAPR, Military Disclosures and Prohibited Credit Terms 24.2 TCPA Calling Technology, Consent and Do-Not-Call Rules 24.3 Telephone Enforcement, TSR Coverage and Commercial Email
25 25. Electronic Consent and Consumer Leasing
25.1 E-SIGN Consent and Consumer Electronic Records 25.2 Consumer Leasing Coverage, Disclosures and Residual Value
26 26. Deposit Insurance and Privacy Notices
26.1 FDIC Insurance: Single, Joint and Trust Ownership 26.2 Retirement, Business and Custodial Insurance; FDIC Signs 26.3 Privacy Notices, Sharing and Opt-Out Opportunities
27 27. Privacy Sharing and Information Security
27.1 Privacy Sharing Exceptions, Account Numbers and Reuse 27.2 Information Security Programs and Incident Investigation 27.3 Customer Incident Notices and Regulatory Notification Clocks
28 28. Authentication and Specialized Data Privacy
28.1 Authentication, access and layered security 28.2 GDPR scope, lawful processing and incident response 28.3 HIPAA and HITECH in bank services
29 29. Insider Lending and Affiliate Definitions
29.1 Regulation O Insider Definitions and Nonpreferential Credit 29.2 Insider Approvals, Lending Limits and Executive Restrictions 29.3 Affiliate Definitions, Covered Transactions and Collateral
30 30. Affiliate Transactions, Appraisals and Originators
30.1 Low-Quality Assets, Market Terms and Affiliate Limits 30.2 Title XI Valuation Thresholds, Exemptions and Credentials 30.3 Valuation Independence, HPML Appraisals and SAFE Registration
31 31. Garnishment and Financial Records
31.1 Federal Benefit Garnishment: Review, Protection and Notice 31.2 Financial Privacy: Government Requests, Certificates and Exceptions 31.3 Regulation S and financial-record reimbursement
32 32. Bank Security and Insurance Sales
32.1 Bank Bribery and Physical Security Programs 32.2 Security Reporting and Retail Nondeposit Investments 32.3 Consumer protection in bank insurance sales
33 33. Securities Activities and Anti-Bribery Rules
33.1 Regulation R and bank brokerage exceptions 33.2 Regulation U purpose credit and margin collateral 33.3 FIRREA civil penalties and foreign bribery risks
34 34. Payment Systems, Child Privacy and Tax Reporting
34.1 Deposit Classification, Reserve Ratios and Debit Interchange 34.2 Internet Gambling Controls, Child Privacy and Email Rules 34.3 IRS information reporting and backup withholding
35 35. Accessible Banking
35.1 ADA Title III and access to banking services
36 36. CMS Governance and Operating Procedures
36.1 Board of Directors & Senior Management Oversight: Responsibilities, Culture & Resources 36.2 The Three Lines of Defense Model in Bank Compliance 36.3 Compliance Policies and Procedures: Development, Approval Cycles & Operationalization
37 37. Compliance Risk Assessment
37.1 Compliance Risk Assessment: Exposure and Control Evidence 37.2 Residual Risk, Specialized Reviews and Event-Driven Updates 37.3 Risk Scoring, Impact Dimensions and Risk Appetite
38 38. Risk Indicators and Compliance Training
38.1 Compliance Indicators, Emerging Risks and Model Limits 38.2 Legal Training Duties and Role-Based Curriculum 38.3 Board Education, Training Administration and Effectiveness
39 39. Monitoring, Testing and Vendor Diligence
39.1 Monitoring, Independent Assurance and Risk-Based Scoping 39.2 Sampling Objectives, Workpapers and Testing Reports 39.3 Third-Party Planning, Diligence and Contract Design
40 40. Vendor Controls and Complaint Management
40.1 Vendor Monitoring, Fintech Controls and Service-Company Notices 40.2 Complaint Intake, Investigation and Root Cause 40.3 Complaint Reporting, Agency Responses and Systemic Redress
41 41. Regulatory Change and Corrective Planning
41.1 Regulatory Surveillance, Impact Assessment and Gap Analysis 41.2 Change Implementation, Validation and Judicial Stays 41.3 Issue Prioritization, Root Cause and Corrective Plan Design
42 42. Restitution and Examination Management
42.1 Remediation Populations, Restitution and Closure Evidence 42.2 Examination Coordination and Consumer Compliance Ratings 42.3 Supervisory Findings, Responses and Enforceable Actions
43 43. Regulatory Reports and Resubmissions
43.1 Regulatory reporting, corrections and examiner updates
10.2 HMDA Exclusions, Partial Exemptions and Data Points
Key Takeaways Explain This Topic AI
Partial exemptions reduce specified data duties without eliminating all HMDA reporting.
Business-purpose dwelling credit requires analysis of its home-purchase, improvement or refinancing purpose.
Data fields must reflect the covered transaction and applicable exemption rather than one universal field count.
Last updated: October 2026
Structures Excluded from Dwelling Definition
Regulation C explicitly excludes transient and non-residential properties:
Recreational Vehicles (RVs): Campers, travel trailers, and motor homes are excluded, even if used as a primary residence.
Houseboats and Floating Homes: Watercraft are excluded.
Transient Housing: Hotels, motels, bed-and-breakfasts, boarding houses, dormitories, homeless shelters, and residential care facilities (nursing homes, hospices).
C. Statutory Transactional Exclusions (§1003.3(c))
The following credit transactions are expressly excluded from HMDA reporting:
Temporary Financing (§1003.3(c)(3)): Construction-only loans designed to be replaced by permanent financing at a later date, and bridge loans designed to be replaced by separate permanent financing for the same borrower. A short term or anticipated property sale alone does not establish temporary financing. Note: Construction-to-permanent loans that convert to long-term financing in a single close or through the same lender are reportable .
Agricultural Purpose Credit (§1003.3(c)(9)): Any loan or line of credit primarily for an agricultural purpose as defined in Regulation Z (§1026.3(a)).
Vacant Land (§1003.3(c)(2)): Loans secured solely by unimproved vacant land, even if the borrower intends to build a dwelling in the distant future (unless a construction loan contract is entered into simultaneously).
Purchased Loan Pools (§1003.3(c)(1)): Purchases of an interest in a pool of loans, such as mortgage-backed securities (MBS) or loan participation shares where the institution does not hold whole loan ownership.
Preapprovals for Open-End Lines or Home Improvement: Preapproval requests are reportable only for closed-end home purchase loans under a formal preapproval program as defined in §1003.2(b)(2).
4. Reportable Data Fields: The Expanded Dodd-Frank Roster
For covered institutions subject to full reporting, Regulation C mandates over 48 individual data points encompassing loan characteristics, pricing, risk underwriting metrics, and property attributes.
Key Data Field Categories
Universal Loan Identifier (ULI, §1003.4(a)(1)(i)): A unique, alphanumeric identifier assigned to each covered loan or application. The ULI cannot exceed 45 characters and must begin with the institution's 20-character Legal Entity Identifier (LEI) , followed by an internal loan sequence identifier, and ending with a 2-character check-digit generated by the MOD-97-10 algorithm. It must never contain personally identifiable information (such as Social Security numbers).
Loan Purpose (Regulation C data requirements): Categorized as Home Purchase, Home Improvement, Refinancing, Cash-Out Refinancing, or Other.
Preapproval Request (Regulation C data requirements): Whether the application was a request for preapproval under a formal written preapproval program for home purchase closed-end loans.
Construction Method & Occupancy (§1003.4(a)(5), (6)): Construction method is recorded as Site-Built or Manufactured Home. Occupancy type is categorized as Principal Residence, Second Residence, or Investment Property.
Pricing Metrics:
Interest Rate (Regulation C data requirements): The contractual interest rate applying at closing or account opening.
Rate Spread (Regulation C data requirements): The difference between the loan's Annual Percentage Rate (APR) and the Average Prime Offer Rate (APOR) for a comparable transaction published weekly by the FFIEC, reportable when required by the applicable rate-spread instructions; not for every application, purchase or excluded product.
Total Loan Costs or Points & Fees (Regulation C data requirements): Total loan costs or total points and fees under the applicable Section 1003.4 reporting conditions; do not assume every non-TRID loan has a points-and-fees reporting duty.
Origination Charges, Discount Points & Lender Credits (§1003.4(a)(18)-(20)): Disclosed from the Closing Disclosure.
Risk and Underwriting Attributes:
Credit Score (Regulation C data requirements): The credit score or scores relied upon in making the credit decision, along with the commercial scoring model name.
Debt-to-Income (DTI) Ratio (Regulation C data requirements): The ratio of total monthly debt obligations to total monthly gross income relied upon in the underwriting decision.
Combined Loan-to-Value (CLTV) Ratio (Regulation C data requirements): Total debt secured by the property divided by the property's appraised value relied upon in underwriting.
Automated Underwriting System (AUS) Result (Regulation C data requirements): The name of the AUS used (e.g., Desktop Underwriter, Loan Product Advisor) and the system's final recommendation.
Non-Amortizing & Complex Loan Features (Regulation C data requirements): Flags indicating whether the loan contains balloon payments, interest-only payments, negative amortization, or other non-amortizing structures.
Property Value (Regulation C data requirements): The property value relied upon in generating the credit decision (appraisal or automated valuation model).
5. Institutional & Transactional Coverage Matrix
Compliance Dimension Depository Institutions Nondepository Institutions EGRRCPA Partial Exemption
Asset Threshold Preceding Dec 31 CPI threshold (> $59M for 2026) None N/A (Applies to insured depositories & credit unions)
MSA Location Home or branch office in MSA Home/branch office or >= 5 covered loans in MSA Same as underlying institution
Closed-End Volume >= 25 loans in each of prior 2 years >= 25 loans in each of prior 2 years < 500 loans in each of prior 2 years
Open-End Volume >= 200 lines in each of prior 2 years >= 200 lines in each of prior 2 years < 500 lines in each of prior 2 years
CRA Requirement General examination standard Not subject to CRA Not two most-recent Needs-to-Improve ratings and not a most-recent Substantial-Noncompliance rating
- Reporting Burden Full 48+ data fields Full 48+ data fields Relieved of 26 fields; must report 22 core fields
- Complete the depository coverage tests
Depository coverage also requires at least one home-purchase loan, or refinancing of a home-purchase loan, secured by a first lien on a one-to-four-family dwelling in the preceding calendar year. This loan-activity test is separate from the two-year origination-volume threshold. The federal-relatedness test can be satisfied by federal insurance or regulation, or by the qualifying loan being federally insured, guaranteed or supplemented, or intended for sale to Fannie Mae or Freddie Mac. Meeting only the four items in a shortened onboarding checklist is insufficient. After establishing institutional coverage, test whether the institution meets the threshold for the particular closed-end or open-end product category and then apply transaction exclusions.