Regulation C

HMDA, CRA and Section 1071 are three separate federal reporting regimes. HMDA (Regulation C) covers applications for dwelling-secured loans. CRA data reporting covers small business, small farm and community development loans at banks above the small bank size. Section 1071 (Regulation B, subpart B) will cover small business credit applications at lenders that originate at least 1,000 a year for two years running. They overlap more than their names suggest. All three hang on a census tract, two of them ask about demographics, and one loan can look like it belongs on two registers when the rules put it on only one. Below, the three sit side by side. Every threshold and date below comes from the current regulation text or the agency notice that set it, and the sources are listed at the…

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The short version. If you have been told HMDA Plus is coming, the date is wrong by about a decade. It is the industry nickname for the expansion the CFPB proposed in 2014 and finalised on 15 October 2015, and most of it took effect on 1 January 2018. It is not a proposal you need to prepare for. It is the reason your LAR looks the way it does now. That matters more than a correction, because a good deal of the material still circulating about it is written in the future tense. If your process was built after 2018 you inherited the outcome without seeing the transition; if it was built before, some of the workarounds from that first filing season are probably still in it. Either way the useful question is not what HMDA Plus proposed. It is what it did to the workflow, and which of those…

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