Now that you’ve had a whole two weeks to get all of the TRID changes implemented (that’s supposed to be funny), the CFPB has issued a Final Rule for HMDA. It’s a mere 796 pages. There’s also a 5 page Executive Summary, a Key Date Timeline, a Regulatory Reference Chart and an Institutional Coverage Flowchart which appear to be helpful.
Here’s some good news:
1) The new rules are not effective until January 2018. That’s right. The kind hearted CFPB gave you an extra year before you need to implement these changes.
2) Beginning in January 2017, if your institution didn’t originate at least 25 home purchased loans (or refinancings of home purchase loans) in each of the two prior years, your institution is exempt from HMDA. Refer to the Institutional Coverage Flowchart (left side, last decision point).
Rest assured, we will be reading and reading and reading the final rule and will prepare a summary soon. When it’s ready, we’ll tell you all about it in our monthly newsletter. We will also plan to have multiple training sessions on the new rules in 2016 and 2017, so you can be prepared.
Now if you’ll excuse me, I’ve got some reading to do!