PROPOSED HMDA CHANGES

On May 2, 2019 the Consumer Financial Protection Bureau (CFPB) published a Notice of Proposed Rulemaking (NPRM), an Advanced Notice of Proposed Rulemaking (ANPR) and other items related to changes to Regulation C, which is the implementing regulation for the Home Mortgage Disclosure Act.

 Notice of Proposed Rulemaking

For closed-end mortgage loans, the NPRM proposes two alternatives that would permanently increase the coverage threshold from 25 to either 50 or 100 closed-end mortgage loans. For open-end lines of credit, the NPRM would extend for another two years the current temporary coverage threshold of 500 open-end lines of credit. Once that temporary extension expires, the NPRM would set the open-end threshold permanently at 200 open-end lines of credit. Comments on the NPRM will be accepted for 30 days following publication in the Federal Register, which is expected soon.

 The 275-page NPRM is available at: https://files.consumerfinance.gov/f/documents/cfpb_nprm-hmda-regulation-c.pdf

 Advanced Notice of Proposed Rulemaking

The ANPR solicits comments about the costs and benefits of collecting and reporting the data points the 2015 HMDA Rule added to Regulation C and certain preexisting data points that the 2015 HMDA Rule revised. The ANPR also seeks comments about the costs and benefits of requiring that institutions report certain commercial-purpose loans made to a non-natural person and secured by a multifamily dwelling. Comments on the APRN will be accepted for 60 days following publication in the Federal Register, which is expected soon.

 The 16-page ANPR is available at:  https://files.consumerfinance.gov/f/documents/cfpb_anpr_home-mortgage-disclosure-regulation-c-data-points-and-coverage.pdf

 Additional Items. 

The CFPB also published to their website a three-page summary of the NPRM and ANPR. The summary is available at:  https://files.consumerfinance.gov/f/documents/cfpb_hmda-regulation-c_summary-2019-proposed-amendments.pdf

The CFPB also published to their website a 25-page  redline copy of the changes. The redline is available at:  https://files.consumerfinance.gov/f/documents/cfpb_hmda-regulation-c_redline-2019-proposed-amendments.pdf

These proposed changes could have a profound impact on some institutions. We would like to hear your comments about the proposal. Please share your comments on our HMDA Forum.

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