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Financial Services Law Insights and Observations

CFPB updates HMDA Small Entity Compliance Guide

Agency Rule-Making & Guidance CFPB HMDA Compliance Mortgages

Agency Rule-Making & Guidance

On May 27, the CFPB issued an updated HMDA Small Entity Compliance Guide to reflect the changes made to Regulation C by the April final rule, which permanently raised coverage thresholds for collecting and reporting data about closed-end mortgage loans and open-end lines of credit (covered by InfoBytes here). The final rule, which amends Regulation C, increases the permanent threshold from 25 to 100 loans starting July 1, 2020, for both depository and nondepository institutions. The final rule also increases the permanent threshold for collecting and reporting data about open-end lines of credit from 100 to 200, but this change will not take effect until January 1, 2022, when the current temporary threshold of 500 open-end lines of credit expires. Beginning in 2022, both depository and nondepository institutions that meet this threshold must report data on open-end lines of credit by March 1 of the following calendar year. The Guide also notes the CFPB’s statement that, as of March 26, 2020, it “does not intend to cite in an examination or initiate an enforcement action against any institution for failure to report its HMDA data quarterly.”

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