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
CLA’s financial institution regulatory compliance team assists banks and credit unions nationwide in establishing regulatory compliance programs, conducting compliance testing, and training staff on regulations. Justin Robinson is a member of CLA’s regulatory compliance team and can be reached at justin.robinson@CLAconnect.com.
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