ComplianceJune 04, 2019

HMDA update: April 26, 2019 proposed changes to HMDA (Issued May 2, 2019)

On April 26, 2019, the Director of the Consumer Financial Protection Bureau (CFPB) signed two items: (1) Advance notice of proposed rulemaking relating to home mortgage disclosure (Regulation C) data points and coverage; and (2) Proposed rule with request for public comment. In addition, the CFPB provided two more documents on their website: (3) Summary of the 2019 HMDA proposed rule relating to coverage thresholds and partial exemptions, and advance notice of proposed rulemaking relating to certain data points and coverage of certain commercial purpose transactions; and (4) Unofficial redline of the HMDA NPRM's proposed amendments to Regulation C. You may find the documents on the CFPB's website at:

The CFPB proposes to increase the thresholds for closed-end and open-end originations. The first part of the proposal is to increase the closed-end threshold to either 50 or 100 originations. The second part of the proposal is to extend the temporary open-end threshold of 500 originations until January 1, 2022, and then settle the open-end threshold at 200 originations. If it comes to fruition, the effect will be that Financial Institutions that do not meet the respective thresholds in each of the two preceding years will not be required to report HMDA data under Regulation C. The CFPB proposes a January 1, 2020 effective date.

Additionally, the CFPB proposes to incorporate the current partial reporting exemptions into Regulation C and provide additional reporting guidance. The CFPB is seeking comments on the above proposals as well as comments on the benefits and burdens of the discretionary data points (those data points that are not required by Dodd Frank). Comments will be due 60 days after publication of the notice in the Federal Register.

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