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:
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.
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 –
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