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OCC BULLETIN 2011-5
To: Chief Executive Officers and Compliance Officers of All National Banks, Department and Division Heads, and All Examining Personnel

Description: Exemption Threshold for Depository Institutions Under Regulation C

On December 23, 2010, the Board of Governors of the Federal Reserve System (the Board) published in the Federal Register the attached final rule amending the staff commentary that interprets the requirements of Regulation C. By this amendment, the Board has raised the asset size exemption threshold to $40 million for depository institutions that are required to report data under the Home Mortgage Disclosure Act (HMDA). The previous exemption level was $39 million. Institutions with assets of $40 million or less as of December 31, 2010, will not be required to collect HMDA data in 2011. This revision is mandated by provisions of the Economic Growth and Regulatory Paperwork Reduction Act of 1996. The adjustment reflects changes in the Consumer Price Index for Urban Wage Earners and Clerical Workers for the 12-month period ending in November 2010.

An institution’s exemption from collecting data in 2011 does not affect its responsibility to report the data it was required to collect in 2010. The adjustment is effective January 1, 2011.

If there are questions on this adjustment or any other HMDA-related issue, please contact the HMDA help line at (202) 452-2016 or send an e-mail to hmdahelp@frb.gov. Questions may also be addressed to your supervisory office or to the Compliance Policy Division at (202) 649-5470.


Calvin R. Hagins
Acting Deputy Comptroller for Compliance

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