Study guide
10.1 HMDA Institutional and Loan Coverage
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
10.1 HMDA Institutional and Loan Coverage
Key Takeaways Explain This Topic AI
HMDA reporting requires both institutional coverage and covered transaction analysis.
The closed-end and open-end volume thresholds are separate tests.
A dwelling-secured transaction can still fall within a specific reporting exclusion.
Last updated: October 2026
1. Institutional Coverage Criteria (12 CFR §1003.2(g))
An institution must determine its HMDA coverage status annually on January 1 by evaluating its operations, asset size, office locations, and loan origination volume during the preceding two calendar years.
A. Depository Institutions (§1003.2(g)(1))
A bank, savings association, or credit union is a covered depository financial institution if it satisfies all four of the following criteria:
Asset Size Threshold: On December 31 of the preceding calendar year, the institution had assets exceeding the annual statutory asset threshold established by the CFPB (indexed annually based on the Consumer Price Index for Urban Wage Earners and Clerical Workers; $59 million for 2026 data collection, tested against December 31, 2025 assets).
Location Test: On December 31 of the preceding calendar year, the institution had a home office or branch office located in a Metropolitan Statistical Area (MSA).
Federal Insurance or Regulatory Test: On December 31 of the preceding calendar year, the institution was federally insured (FDIC or NCUA) or federally regulated.
Loan-Activity Volume Threshold: The institution meets either the closed-end mortgage loan threshold or the open-end line of credit threshold:
Closed-End Mortgage Loans: Originated at least 25 closed-end mortgage loans in each of the two preceding calendar years.
Open-End Lines of Credit: Originated at least 200 open-end lines of credit in each of the two preceding calendar years.
Judicial History Note on the Closed-End Threshold: In 2020, the CFPB issued a final rule raising the closed-end threshold from 25 to 100 loans. However, in September 2022, the U.S. District Court for the District of Columbia in National Community Reinvestment Coalition (NCRC) v. CFPB vacated the 100-loan threshold, reinstating the statutory 25 closed-end loan threshold retroactively. Compliance programs must track the 25-loan threshold for closed-end origination volume.
B. Nondepository Institutions (§1003.2(g)(2))
A for-profit mortgage company or nondepository lender is a covered financial institution if it meets two criteria:
Location Test: On December 31 of the preceding calendar year, the institution had a home or branch office in an MSA, OR received applications for, originated, or purchased five or more covered loans secured by dwellings located in an MSA.
Loan-Activity Volume Threshold: Originated at least 25 closed-end mortgage loans in each of the two preceding calendar years, OR originated at least 200 open-end lines of credit in each of the two preceding calendar years.
2. EGRRCPA Partial Exemptions (§1003.3(d))
Section 104 of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018 (EGRRCPA) created relief for community banks and smaller lenders by providing a partial exemption from reporting 26 expanded Dodd-Frank data fields.
A. Origination Thresholds for Partial Exemption
Closed-End Mortgage Relief: An insured depository institution or insured credit union is exempt from reporting the 26 expanded fields for closed-end loans if it originated fewer than 500 closed-end mortgage loans in each of the two preceding calendar years.
Open-End Line of Credit Relief: An institution is exempt from reporting the expanded fields for open-end lines if it originated fewer than 500 open-end lines of credit in each of the two preceding calendar years.
B. The Community Reinvestment Act (CRA) Rating Prerequisite
The partial exemption is strictly conditioned on the institution's fair lending and community reinvestment track record. An insured depository institution is disqualified from the partial exemption if:
It received a CRA rating of "Needs to Improve" on each of its two most recent CRA examinations; or
It received a CRA rating of "Substantial Noncompliance" on its most recent CRA examination.
Compliance Rule: If disqualified due to poor CRA ratings, the institution must collect and report the applicable expanded HMDA data points without that partial exemption even if it originates fewer than 500 loans.
C. Scope of the Partial Exemption
Qualifying institutions under the partial exemption are relieved from reporting 26 complex data fields (including property value, credit score, DTI, CLTV, total loan costs, rate spread, and AUS results). However, they must continue to collect and report 22 core HMDA data fields , including:
- Legal Entity Identifier (LEI) / Non-Universal Loan Identifier (NULI);
- Application date, action taken, and action taken date;
- Loan type, loan purpose, and loan amount;
- Preapproval request indicator;
- Construction method and occupancy type;
- Property location (state, county, census tract);
- Lien status;
Applicant demographic information (ethnicity, race, and sex).
Institutions may voluntarily choose to report any or all exempt data points, but if they voluntarily report an exempt field, they must report all associated sub-elements accurately.
3. Transactional Coverage (12 CFR §1003.2(e), §1003.3)
HMDA transactional coverage is evaluated at the application level. A transaction is covered if it involves a covered loan secured by a dwelling .
A. Covered Loans (§1003.2(e))
A covered loan is any closed-end mortgage loan or open-end line of credit secured by a dwelling, divided into consumer-purpose and commercial-purpose credit:
Purpose Classification Coverage Standard Operational Rule
Consumer-Purpose Credit Covered regardless of purpose Any consumer-purpose credit secured by a dwelling is reportable, including home purchase, home improvement, refinancing, and other personal purposes (e.g., debt consolidation or education loans secured by a residential home).
Commercial-Purpose Credit Covered ONLY IF specific housing purpose A business- or commercial-purpose loan secured by a dwelling is reportable only if the transaction is for home purchase , home improvement , or refinancing . Other commercial loans secured by a dwelling (e.g., working capital or equipment financing secured by an apartment building) are excluded .
B. The Regulatory Definition of "Dwelling" (§1003.2(f))
Under Regulation C, a dwelling is defined as a residential structure, whether or not attached to real property. The definition includes:
- 1-to-4 family residential properties (single-family detached, duplexes, triplexes, fourplexes);
- Individual condominium units and cooperative units;
- Manufactured homes and mobile homes (regardless of whether titled as real property or personal property);
Multifamily residential structures (apartment buildings with 5 or more units).