Newsroom

August 24, 2017

CFPB finalizes HELOC reporting changes under HMDA

The CFPB on Thursday finalized its proposed changes to its Home Mortgage Disclosure Act rule that would temporarily raise the home equity line of credit reporting threshold for smaller financial institutions, including credit unions.

As previously issued, the HMDA rule required credit unions to report HELOCs if they made 100 such loans in each of the last two years. Thursday's final rule increases that threshold to 500 loans through calendar years 2018 and 2019 while the bureau considers whether to make the change permanent.

In NAFCU's comment letter on the CFPB's proposal, sent in July, the association urged an exemption from HMDA reporting for all HELOCs or, in the alternative, make the 500 loan threshold permanent. NAFCU will reengage with the bureau to ensure these recommendations are addressed.

In addition, NAFCU urged that the CFPB raise the asset-size exemption for covered institutions from $44 million to $100 million, matching the regulatory definition of a "small" credit union; and delay effective date of the bureau's 2015 HMDA rule changes one year to Jan. 1, 2019.

The CFPB's finalized rule also contains some clarifications, technical corrections and minor changes to the HMDA regulation. These include clarifying key terms, such as "temporary financing" and "automated underwriting system."

In general, the CFPB's final HMDA rule changes are set to take effect Jan. 1, with most data submissions under the new provisions due in 2019. The rule changes affect HELOCs, establish transactional thresholds for coverage and expand the number of HMDA data points to be collected from credit unions.