As I’m sure you are well aware, under the new HMDA rules, a bank (that meets the asset threshold test, Metropolitan Statistical Area (MSA) test, and originated at least one home purchase/refinance loan secured by a 1st lien on a 1-4 family dwelling), is subject to HMDA data collection in 2018, IF in the prior two calendar years (2017 and 2016) the bank originated at least:
- 25 closed-end dwelling secured loans; OR,
- 100 open-end lines of credit secured by a dwelling.
There may be some good news on the horizon for some of you! Due to concerns that the open-end transaction coverage threshold (100) is too low, the CFPB has proposed to temporarily increase that threshold to 500 for two years (calendar years 2018 and 2019). This means that financial institutions originating fewer than 500 open-end lines of credit in either of the preceding two years would not be required to collect and report data with respect to open-end credit.
To put that in plain English:
You’re required to report 2018 open-end credit if you originated 500 or more open-end lines in both 2016 and 2017. If you originate less than 500 open-end lines in 2017 you won’t have to report open-end lines in 2018 or 2019. That’s really all you need to know for now. Beyond that we’ll take the wait and see approach. Stay tuned!
If you’re looking for training on the upcoming HMDA changes, we have multiple webinars and live events coming up. Whether you need a full overview or just training on specific areas, we’ve got you covered. Check out our store for more information.
Deb joined Banker’s Compliance Consulting with twenty years of experience in the banking industry. Her past positions include teller, credit review analyst, assistant financial officer, BSA Officer, Compliance Officer, and Director of Compliance. She has worked for both a small community bank and a large billion-dollar bank.
Deb has Associate Degrees in Business Management and Accounting. She is a graduate of the American Bankers Association National Graduate School of Compliance Management, an honors graduate of Schools of Banking Compliance School, and a graduate of Schools of Banking Advanced School of Banking. Deb’s considerable knowledge and experience make her a valuable member of the Banker’s Compliance Consulting Team. Deb is a Certified Regulatory Compliance Manager (CRCM) and a Certified Anti Money-Laundering Specialist (CAMS).
Deb loves to spend her free time cycling, running, kayaking and weight lifting with her husband. Between them, they have three adult children and six grandchildren. Other interests include anything outdoors and anything she hasn’t done or seen yet!