1) The credit union's assets total more than $44 million as of December 31, 2017,

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1 Exemption: This regulation only applies if the following criteria are met: 1) The credit union's assets total more than $44 million as of December 31, 2017, 2) The credit union has a home or branch office in a Metropolitan Statistical Area; 3) The credit union has, in the preceding calendar year, originated at least one first lien home purchase loan (closed end mortgage loan or an open end line of credit that is for the purpose, in whole or in part, of purchasing a dwelling) or refinance of a home purchase loan, secured by a first lien on a one to four family dwelling and meets one of the following conditions: a. The credit union is federally insured or regulated; b. The home purchase loan is insured, guaranteed or supplemented by a federal agency; or c. The home purchase loan is intended for sale to the Federal National Mortgage Association (FNMA) or the Federal Home Loan Mortgage Corporation (FHLMC); AND 4) In each of the two preceding years, the credit union: a. Originated at least 25 closed end mortgage loans (not otherwise excluded); OR b. Originated at least 500 open end lines of credit (secured by a lien on a dwelling) that are not otherwise excluded. Compliance Factor Description Area Name : Loans Item Name : Home Mortgage Disclosure Act (HMDA) Factors List : Factors Name Factors Description Definitions For purposes of HMDA coverage, the credit union utilizes the following definitions within their policies and procedures: 1. Closed-end mortgage loan an extension of credit that is secured by a lien on a dwelling and that is not an open-end line of credit. 2. Dwelling - a residential structure, whether or not attached to real property. The term includes, but is not limited to a detached home, an individual condominium or cooperative unit, a manufactured home or other factory-

2 built home, or a multifamily residential structure or community. Dwelling is not limited to the principal or other residence of the borrower and includes vacation or second homes and investment properties. Recreational vehicles, including boats, campers, travel trailers and park model recreational vehicles are not considered dwellings (regardless of whether they are used as residences) 3. Home improvement loan a closed-end mortgage loan or an open-end line of credit that is for the purpose, in whole or in part, of repairing, rehabilitating, remodeling, or improving a dwelling or the real property on which the dwelling is located. 4. Home purchase loan a closed-end mortgage loan or an open-end line of credit that is for the purpose, in whole or in part, of purchasing a dwelling. 5. Open-end line of credit an extension of credit that is secured by a lien on a dwelling; and an open-end credit plan for which the credit union reasonably contemplates repeated transactions, the credit union may impose a finance charge from time-to-time on an outstanding unpaid balance, and the amount of credit that may be extended to the borrower during the term of the plan (up to any limit set by the credit union) is generally made available to the extent that any outstanding balance is repaid. Covered Loans and Transactions 1. The credit union has policies and procedures in place to collect data on most dwelling-secured loans including closed-end mortgage loans or open-end lines of credit that are not otherwise excluded. 2. The credit union obtains HMDA data for reporting for the following transactions: a. Home Purchase Loans secured by and made for the purpose of purchasing a residential dwelling (not limited to principal dwellings). b. Home improvement loans either open-end or closed-end that are for the purpose, in whole or in part, of repairing, rehabilitating, remodeling or improving a dwelling or the real property on which the dwelling is located. c. Refinancing for open-end or closed-end loans in which a new, dwelling secured obligation satisfies and replaces an existing dwelling-secured debt obligation by the same borrower. d. Commercial or business loans that are dwelling secured and meet the definition of home purchase loans, home improvement loans or refinancing. Reportable Loan Data 1. The credit union collects data regarding applications for covered loans that it receives, originates and purchases each calendar year. (1003.4(a))

3 2. The credit union collects data under a preapproval program (defined in (b)(2)), only if the preapproval request is denied, is approved by the credit union, but not accepted by the applicant, or results in the origination of a home purchase loan. 3. The data collected includes the following items: a. Credit Union s Legal Entity Identifier. b. A Universal Loan Identifier. c. Date the application was received. d. Type of loan or application (conventional, FHA insured, VA guaranteed, FSA/RHS guaranteed). e. Purpose of the loan or application (purchase, home improvement, refinancing, etc.). f. Preapproval (if the loan was initiated as a request for a preapproval under a preapproval program).. g. Construction method (whether the dwelling is site-built or a manufactured home). h. Owner-occupancy status of the property to which the loan or application relates (principal residence, second residence, investment property, etc.). i. Amount of the loan or the amount applied for. j. Type of action taken, and the date. k. Property address (securing the loan). l. Location of the property (if the property is located in a MSA or Metropolitan Division where the credit union has a home or branch office, the location by State, County, Census Tract). m. Ethnicity, race, and sex of the applicant or borrower (and if the information was collected by visual observation or surname). n. Age.

4 o. Income (the gross annual income relied on in processing the application). p. Type of entity that purchased the loan. q. Rate spread between the annual percentage rate (APR) and the average prime offer rate (APOR) for a comparable transaction. r. Whether the loan is subject to the Home Ownership and Equity Protection Act (HOEPA). s. Lien status of the loan or application (first lien or subordinate lien). t. Credit score (credit score(s) relied on and the name and version of the credit scoring model). u. Reason for denial. v. Total loan costs or total points and fees (either total loan costs or total points and fees charged). w. Origination charges (total borrower paid origination charges). x. Discount points (points paid to the credit union to reduce the interest rate). y. Lender credits. z. Interest rate. aa. Prepayment penalty term (term in months of any prepayment penalty). bb. Debt-to-income ratio. cc. Combined loan-to-value ratio. dd. Loan term. ee. Introductory rate period (number of months until the first date the interest rate may change). ff. Non-amortizing features (balloon payment, interest-only payments, negative amortization, etc.). gg. Property value. hh. Manufactured home secured property type (whether loan is secured by a manufactured home and land or a manufactured home and not land).

5 ii. Manufactured home land property interest (ownership or leasehold interest in the land where the manufactured home is located). jj. Total units (number of individual dwelling units related to the property). kk. Multifamily affordable units (number of units related to property that are income-restricted under federal, state, or local affordable housing programs). ll. Application channel (submission of application and if initially payable to the credit union). mm. Mortgage loan originator NMLSR identifier. nn. Automated underwriting system (name of the automated underwriting system used by the credit union to evaluate the application and the results generated by the system). oo. Reverse mortgage. pp. Open end lines of credit. qq. Business or commercial purpose. Disclosure and Reporting 1. By March 1st following the calendar year for which the loan data are compiled, the credit union sends its complete loan/application register (LAR) electronically to the Consumer Financial Protection Bureau (CFPB). 2. The credit union retains a copy of HMDA LAR information for at least three years. (1003.5) 3. Upon request, the credit union makes available the disclosure statement prepared by the Federal Financial Institutions Examination Council (FFIEC) based on the credit union s data submitted the preceding calendar year, no later than 3 business days after receiving notice from the FFIEC of its availability, by providing written notice similar to the safe harbor language: Home Mortgage Disclosure Act Notice The HMDA data about our residential mortgage lending are available online for review. The data show geographic distribution of loans and applications; ethnicity, race, sex, age and income of applicants and borrowers; and information about loan approvals and denials. These data are available online at the Consumer Financial Protection Bureau s Web site

6 ( HMDA data for many other financial institutions are also available at this Web site. a. This written disclosure statement is made available to the public for a period of five years. 4.. Upon request, the credit union makes its modified loan/application register (LAR) available by providing written notice that clearly conveys that the credit union s modified LAR may be obtained on the CFPB s website using the same safe harbor language listed above. a. The written notice for the modified loan/application register is available to the public for a period of three years. 5. The credit union displays the following disclosure (or something similar) in the lobby of their home office and each branch office physically located in each metropolitan statistical area (MSA) and each metropolitan district (MD): Home Mortgage Disclosure Act Notice The HMDA data about our residential mortgage lending are available online for review. The data show geographic distribution of loans and applications; ethnicity, race, sex, age, and income of applicants and borrowers; and information about loan approvals and denials. HMDA data for many other financial institutions are also available online. For more information, visit the Consumer Financial Protection Bureau s Web site ( Data Collection 1. The credit union includes a list of questions regarding ethnicity, race and sex on the loan application or a separate form that refers to the application. Although, the credit union does not require the applicant to respond and provide the information. 2. The questions are asked orally for phone applications. 3. The credit union informs applicants that Federal law requires this information to be collected in order to protect consumers and to monitor compliance with Federal statutes that prohibit discrimination against applicants on these bases. The credit union also informs the applicant that if the information is not provided, where the application is taken in person, the credit union is required to note the information on the basis of visual observation or surname. 4. The credit union reports the ethnicity, race and sex of an applicant as provided by the applicant. 5. The credit union offers the applicant the option of selecting more than one

7 ethnicity or race. If the applicant selects more than one ethnicity or race, the credit union reports each selected designation. 6. If the applicant chooses not to provide the information, then the credit union notes the information on the application, if taken in person and then collects the ethnicity, race and sex on the basis of visual observation or surname. If the application is taken over the phone or internet, and the applicant declines to provide the information, it does not need to be collected and the credit union reports information not provided by applicant in mail, internet or telephone application. 7. If the applicant provides the requested information for some but not all of the fields, the credit union reports the information that was provided by the applicant, whether partial or incomplete. (Appendix B)