October 13, 2017

CFPB's HELOC changes covered in updated compliance guide

The CFPB updated its Home Mortgage Disclosure Act (HMDA) small-entity compliance guide to incorporate recent changes that temporarily raise the home equity line of credit (HELOC) reporting threshold for smaller financial institutions, including credit unions.

The CFPB's final HMDA rule, issued in August, increases the threshold at which credit unions are required to report HELOCs from 100 to 500 loans through calendar years 2018 and 2019. NAFCU continues to urge the CFPB for an exemption from HMDA reporting for all HELOCs or, in the alternative, make the 500-loan threshold permanent.

The CFPB's final rule also contains some clarifications, technical corrections and minor changes to the HMDA regulation, and those are reflected in this updated guide. The guide also reflects changes on the reporting of census tract data using the geocoding tool provided by the bureau.

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.

The association has a host of HMDA compliance resources available to association members, including charts and guides, articles, webcasts and blog posts.