Proposed HMDA Changes

Yesterday, the CFPB issued a proposal that seeks to make changes to the existing HMDA Rule.  They also issued an Advance Notice of Proposed Rulemaking (ANPR) to solicit comments as to whether certain other changes are needed.



The proposed changes include:


1. Raising the HMDA coverage threshold


For closed-end mortgage loans the proposal seeks to permanently increase the current threshold of 25 to either 50 or 100.  This would mean that if you stay below the threshold in either of the two preceding calendar years, you would not have to report closed-end loans as of January 1, 2020.

For open-end lines of credit, the proposal seeks to extend the temporary (and current) threshold of 500 for another two years (until January 1, 2022).  After that date, the proposal seeks to set the threshold permanently at 200.


2. Small Filers


The proposal also seeks to incorporate the Small Filer exemptions into the Regulations.



The ANPR seeks comment on the following:


1. HMDA Data Points


The CFPB is requesting input on the current data fields to determine if they should make any changes or require additional data to be reported.  Specifically, they want to assess if the data requirements appropriately balance the benefits and burdens associated with data reporting.  The CFPB has set out four topics they would like comments to address with respect to the data fields (see page 13 of the ANPR).



2. HMDA Coverage for Certain Business/Commercial Loans


The proposal also requests comments as to whether reporting business/commercial purpose loans extended to a non-natural person (and secured by a multifamily dwelling) are a burdensome and/or whether data actually useful to the CFPB.  Page 15 of the ANPR outlines what they want comments to address.


If you’re still struggling with the existing HMDA Rules, we have a variety of HMDA webinars available On-Demand.  Be sure to check them out!




Want to know more about HMDA? – https://www.bankerscompliance.com/banking-regulations-compliance-services/reviews-2/hmda/

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