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John Zasada, Compliance Consulting Director, Financial Institutions Group

As we approach 2022, your institution should be sure it’s ready to implement new changes to the Home Mortgage Disclosure Act (HMDA) reporting requirements for closed-end mortgage loans, and Home Equity Lines of Credit (HELOCs) previously announced by the Consumer Financial Protection Bureau (CFPB).

Back on July 1, 2020, a financial institution that originated at least 100 closed-end mortgage loans in each of the two preceding calendar years or originated at least 500 HELOCs in each of the two preceding calendar years would meet or exceed the HMDA loan-volume threshold. On Jan. 1, 2022, this temporary threshold of 500 HELOCs expires, and a financial institution that originates at least 100 closed-end mortgage loans in each of the two preceding calendar years or originates at least 200 HELOCs in each of the two preceding calendar years will meet or exceed the loan-volume threshold.

The partial exemption for reporting specific data points applies to an eligible financial institution’s applications for, originations of, and purchases of closed-end mortgage loans if the bank originated fewer than 500 closed-end mortgage loans in each of the two preceding calendar years. A partial exemption applies to an eligible financial institution’s applications for, originations of, and purchases of HELOCs if it originated fewer than 500 HELOCs in each of the two preceding calendar years.

Want to make sure your financial institution is in compliance with new HMDA thresholds? Contact our regulatory compliance specialists today.