CFPB Compliance Deadline: HMDA (Regulation C) Phase 2

January 1, 2018

The CFPB has issued a final rule making several substantive revisions to Regulation C's reporting requirements under the Home Mortgage Disclosure Act (HMDA). With the changes, the class of covered transactions now includes most dwelling-secured openend and closed-end lending, effectively mandating reporting on HELOCs. The final rule also expands the HMDA data set, requiring credit unions to report on a total of roughly 38 data points. The modified institutional coverage test will be implemented under a "phased in" schedule.

Phase 2 – A credit union will not report HMDA data unless it meets the asset-size, location, federally related, and loan activity tests and it originates 25 or more covered closed-end mortgage loans or 100 or more covered open-end lines of credit in each of the two preceding calendar years.

NAFCU Final Regulation Summary: 15-EF-17

NAFCU Compliance Blog: February 26, 2016

NAFCU Compliance Monitor: November 2015

Download the latest full Compliance Calendar, including proposed regulations, past deadlines and more.