Credit unions face several important compliance deadlines in 2018. Even though the industry has had months and in some cases years to prepare for these changes, we have heard firsthand that there will be a fair amount of last-minute scrambling to become fully compliant. Let’s look at several of the compliance deadlines and briefly describe what is changing.
Jan. 1, 2018, was the effective date for most of the requirements in the new Home Mortgage Disclosure Act rule, including institutional and transactional coverage, data collection, disclosures and reporting. The new rule added 25 new data fields and modified 20 of the 23 previously existing fields. Covered credit unions should have begun collecting the information on Jan. 1, 2018, and will report it by March 1, 2019.
A credit union is subject to the HMDA requirements if it originated at least 25 covered closed-end mortgage loans or at least 500 covered open-end lines of credit in each of the two preceding calendar years, and if it meets current Regulation C asset-size, location, federally-related and loan activity tests.
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