Well, it’s here. After almost a year of waiting to see what the CFPB was going to do with the permanent HMDA thresholds for both open-end and closed-end loans, we have an answer!
The closed-end threshold is being raised to 100, effective July 1, 2020, and the open-end threshold is moving to 200, effective January 1, 2022. When determining where you fall, you still look at the previous two years. For example, if you originated at least 100 closed-end loans in each of the prior two years, you will report closed-end loans for HMDA. Come January 1, 2022, if you originated 200 open-end lines of credit in each of the prior two years, you will need to collect HMDA data for open-end lines (to be reported in 2023).
First-Quarter HMDA Data
Note that the rule is effective July 1, 2020. If this change means you will no longer be a closed-end reporter, you do still need to record your first-quarter HMDA data on your LAR (by April 30th) AND you must continue collecting HMDA data until July. However, you won’t be required to report any of your 2020 data.
We hope this is good news for many of you at a time when you could really use some! As with any change, good or bad, there are some things to consider, like what do you need to do before and after July 1st? Let us walk you through the changes and your next steps! Join us on April 23, 2020, as we discuss the NEW! 2020 HMDA Final Rule!