HMDA HELOC Proposal

On July 14, the Consumer Financial Protection Bureau (CFPB) issued a proposal to change the home equity line of credit (HELOC) reporting threshold for Home Mortgage Disclosure Act (HMDA) purposes. Under the current HMDA rules, financial institutions are required to report HELOCs if they made 100 HELOC loans in each of the last two years. The 39 page proposal would increase that threshold to 500 loans for calendar years 2018 and 2019.  The CFPB then will determine whether to make the change permanent.

http://files.consumerfinance.gov/f/documents/201707_cfpb_NPRM_HMDA-temporary-threshold-increases.pdf

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John Zasada is a principal with CLA and leads the firm’s financial institution regulatory compliance practice. He assists banks and credit unions nationwide in establishing regulatory compliance programs, conducting compliance testing, training staff on regulations, and performing website compliance assessments. In addition, John is a frequent speaker at industry conferences and state associations. Prior to joining CLA, he served as managing director at a top-10 accounting firm and as the compliance officer of a large financial institution, where he developed and implemented its first regulatory compliance program.

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