Good News – More HMDA Relief Possible
On May 2, 2019, the Consumer Financial Protection Bureau (CFPB) released a Notice of Proposed Rulemaking (NPRM) and an Advance Notice of Proposed Rulemaking (ANPR) on the Home Mortgage Disclosure Act (HMDA). The 275 page NPRM proposes increasing the threshold for reporting closed-end mortgage loans so that institutions originating fewer than 50 closed-end mortgage loans, or alternatively 100 closed-end mortgage loans, in either of the two preceding calendar years would not have to report the data as of January 1, 2020. The proposal would also adjust the threshold for reporting data about open-end lines of credit by extending to January 1, 2022, the current temporary threshold of 500 open-end lines of credit and setting the threshold at 200 open-end lines of credit after the expiration of the proposed extension of the temporary threshold. The 16 page ANPR seeks comments about the costs and benefits of the changes made to the HMDA requirements in October 2015. It also asks about the costs and benefits of reporting certain commercial-purpose loans made to non-natural persons and secured by multifamily dwellings.
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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