CFPB finalizes temporary increase of HMDA reporting threshold
Thursday, August 31, 2017
On Thursday, August 24, the Consumer Financial Protection Bureau (CFPB) finalized its proposed changes to the Home Mortgage Disclosure Act (HMDA) rule that would temporarily raise the home equity line of credit (HELOC) reporting exclusion for smaller financial institutions.
As previously published, the HMDA rule required credit unions to report open-end lines of credit if they made 100 such loans in each of the previous two years. Thursday's final rule increases that threshold to 500 loans through calendar years 2018 and 2019 while the Bureau considers whether to make the change permanent. Credit unions originating fewer than 500 open-end lines of credit would not be required to begin collecting such data until January 1, 2020.
In a July comment letter on the CFPB's proposal, the Carolinas Credit Union League urged for an even higher exemption cap for reporting HELOCs.
“In general, CCUL supports a temporary increase to the threshold but considers 1,000 open-end lines of credit to be more appropriate,” stated CCUL’s Jeanne Couchois in the letter. “It is CCUL’s position that the CFPB not only raise the temporary threshold to 1,000 but make the increase in the threshold permanent instead of just the two years outlined in the proposed rule.”
CCUL will reengage with the CFPB to ensure these recommendations are considered.
The CFPB's executive summary also highlighted other changes to the final HMDA rule including:
- Establishing a new reporting exclusion and optional reporting for certain transactions and data points; and
- Clarifying certain key terms defined in the 2015 HMDA Rule, including multifamily dwelling and automated underwriting system, among others.
For the most part, the Bureau’s final HMDA rule changes are set to take effect January 1, 2018, with most data submissions under the new provisions due in 2019. The rule changes affect HELOCs, establish transactional thresholds for coverage and expand the number of HMDA data points to be collected from credit unions.
CCUL submits letter on CFPB proposal to temporarily raise HMDA reporting threshold (8/2/17)
CFPB proposed rule to temporarily raise HMDA reporting threshold for smaller CUs (7/19/17)