April 17, 2020

CFPB finalizes increased HMDA data reporting thresholds

CFPBThe CFPB Thursday issued its final rule to raise the data reporting thresholds under the Home Mortgage Disclosure Act (HMDA). NAFCU has flagged for the bureau credit unions' high compliance cost of HMDA reporting and, while it is supportive of the increased thresholds, had recommended even higher thresholds to provide more regulatory relief.

The final rule increases the reporting threshold for closed-end dwelling secured loans from 25 loans in the preceding two calendar years to 100 loans. This change takes effect July 1.

In addition, the rule increases the threshold for reporting open-end lines of credit, including home equity lines of credit (HELOCs), from the original threshold of 100 loans in the 2015 rule to 200 loans effective Jan. 1, 2022.

Until the new threshold takes effect, the temporary threshold of 500 open-end lines of credit, which was extended until 2022 in October, will remain in place.

NAFCU has more on HMDA and its implementing Regulation C available in this Compliance Blog post.