Is anyone else watching Elf and reading the new HMDA and Regulation C rules? Just me?!
The Home Mortgage Disclosure Act (HMDA) requires credit unions to disclose certain information regarding loans originated or purchased by credit unions. HMDA is implemented by the CFPB’s Regulation C which was amended in October to extend the current threshold for reporting data about open-end lines of credit. The rule extends temporary relief but does not make permanent changes to the coverage thresholds for closed-end mortgage loans and open-end lines of credit as originally proposed.
Currently, HMDA establishes a coverage threshold for open-end lines of credit of at least 500 open-end lines of credit in each of the two preceding calendar years. See, 12 CFR § 1003.3(c)(12). Credit unions that have not originated at least 500 open-end lines of credit in each of the two preceding years are excluded from the requirement to report them. However, this threshold for open-end lines of credit was part of a temporary rule effective only for calendar years 2018 and 2019 in order to give the CFPB time to analyze and determine whether this was the appropriate threshold. As the CFPB continues its analysis and considers a permanent threshold for open-end lines of credit, it has decided to extend the 500 loan threshold for 2 more years.
Ultimately, credit unions that originate fewer than 500 open-end lines of credit in each of the two preceding calendar years continue to be excluded from those reporting requirements until January 1, 2022. The CFPB has stated its reasoning for extending the current threshold: “…the temporary coverage threshold of 500 open-end lines of credit will also ensure that institutions that would be required to report under any new permanent threshold that the Bureau sets in 2020 to take effect in 2022 have time to adapt their systems and prepare for compliance.”
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