John Zasada, Compliance Consulting Director, Financial Institutions Group

On April 16, 2020, the Consumer Financial Protection Bureau (CFPB) amended the Home Mortgage Disclosure Act (Regulation C). The 157-page final rule permanently increases the threshold for closed-end mortgage loan reporting, so institutions originating fewer than 100 closed-end mortgage loans in either of the two preceding calendar years will not have to report data effective July 1, 2020. The 2015 HMDA rule set the threshold at 25 closed-end mortgage loans in each of the two preceding calendar years.

The CFPB is also setting the threshold for reporting open-end lines of credit at 200 open-end lines of credit effective Jan. 1, 2022. In 2017, the CFPB temporarily set the open-end threshold at 500 open-end lines of credit for two years (calendar years 2018 and 2019). The temporary threshold of 500 open-end lines of credit expires on Jan. 1, 2022.

For more information on how the HMDA guidance impacts your institution, contact Doeren Mayhew’s compliance specialists.