FINAL HMDA REVISIONS PUBLISHED

On October 10 the Consumer Financial Protection Bureau (CFPB) published a rule that completes portions of the proposed rule, issued last May, to revise the Regulation C coverage thresholds and complete partial Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA) exemptions..

The good news is the final rule:

  • Extends for another two years, until January 1, 2022, the current temporary coverage threshold of 500 open-end lines of credit. For data collection years 2020 and 2021, financial institutions that originated fewer than 500 open-end lines of credit in either of the two preceding calendar years will not need to collect and report data with respect to open-end lines of credit.
  • Incorporates into Regulation C the clarifications from the Bureau’s August 2018 interpretive and procedural rule and also addresses certain issues relating to the partial exemptions that the August 2018 rule did not address.

The bad news is the final rule does not complete the aspects of the proposal that would:

  • Increase the volume threshold that triggers reporting of closed-end mortgage loans from at least 25 originated loans in each of the prior two calendar years to at least 50 (or maybe 100) originated loans in each of the prior two calendar years.
  • Increase the volume threshold that triggers reporting of open-end, dwelling-secured lines of credit to at least 200 originated lines of credit in each of the prior two calendar years.

Note:  The CFPB plans to issue a separate final rule in 2020 addressing these thresholds.

The final HMDA rule, which is generally effective on January 1, 2020, is available at: https://files.consumerfinance.gov/f/documents/cfpb_hmda_final-rule-2019.pdf

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