NEW HMDA REPORTING THRESHOLD

On April 16, 2020 the Consumer Financial Protection Bureau (CFPB) published a final rule amending Regulation C to set the thresholds for reporting data about:

  • Closed-end mortgage loans, so that institutions originating fewer than 100 closed-end mortgage loans in either of the two preceding calendar years will not have to report such data effective July 1, 2020.
  • Open-end lines of credit at 200 open-end lines of credit effective January 1, 2022, upon the expiration of the current temporary threshold of 500 open-end lines of credit.

The Bureau is releasing for this final rule an unofficial, informal redline to assist industry and other stakeholders in reviewing the changes that this final rule makes to Regulation C. The 2020 HMDA Final Rule includes changes with two different effective dates: July 1, 2020 and January 1, 2022. The unofficial redline highlights the changes to regulation text and commentary that take effect on both dates.

  • The changes that the 2020 HMDA Final Rule makes are marked in red. For the July 1, 2020 effective date, the underlying (unmarked) text reflects the relevant provisions in Regulation C as they would have been in effect on July 1, 2020, if the Bureau had not adopted the 2020 HMDA Final Rule, and the redline highlights text that will take effect on July 1, 2020 as adopted by the 2020 HMDA Final Rule.
  • For the January 1, 2022 effective date, the underlying (unmarked) text reflects the relevant provisions in Regulation C as they would be in effect on January 1, 2022 absent this final rule, and the redline highlights text that will take effect on January 1, 2022.

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