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By John Zasada, JD, CAMS – Shareholder, Financial Institutions Group

In a relatively stunning decision, Chief District Court Judge Beryl Howell of the Federal District Court of Washington vacated part of the 2020 Consumer Financial Protection Bureau (CFPB) rule that eased Home Mortgage Disclosure Act (HMDA) reporting requirements for lower mortgage-volume financial institutions.

The 2020 final rule exempted hundreds of financial institutions from having to report HMDA data. Then CFPB Director Kathy Kraninger’s final rule raised the threshold for HMDA reporting from 25 closed-end loans to 100 closed-end loans. She did so in part because “lower-volume institutions continue[d] to experience significant burden” from the reporting requirements.

While the court vacated the 2020 final rule related to closed-end loans, the court kept in place the 2020 final rule related to open end loans.

If you have questions about how this ruling could impact your financial institution’s HMDA policies and procedures, contact our Financial Institution Group’s compliance specialists.