HMDA Reporting Thresholds Increased by CFPB

The Home Mortgage Disclosures Act (HMDA) as implemented by the Consumer Financial Protection Bureau’s Regulation C, 12 CFR Part 1003 (Regulation C), requires *certain depository institutions to collect, and report mortgage data used to:

  • Identify potential discriminatory lending practices;
  • Determine whether lending institutions are serving housing needs of their communities, and
  • Assist public officials in the public investment where efforts are needed.

On April 16, 2020, the CFPB issued the final rule to Regulation C that adjusts the reporting thresholds for closed-end mortgage loans and open-end lines of credit reporting

According to the final rule, institutions that originate fewer than 100 closed-end mortgage loans within “either of the two preceding calendar years” are not required to report closed-end mortgage data effective July 1, 2020.  This change is an increase over the previous 25 closed-end loan disclosure threshold.

Additionally, the threshold for reporting open-end lines of credit will change from 100 to 200 on January 1, 2022, upon the expiration of the current temporary threshold of 500 open-end lines of credit.

 

Sources:

FFIEC, 2020 Edition A Guide to HMDA Reporting: Getting it Right!

*Depository institution determination is made based on asset-size threshold, location test, loan activity, federally insured/federally regulated, meets loan volume threshold –

Federal Register

https://www.federalregister.gov

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