CFPB raises HMDA data reporting threshold

The Consumer Financial Protection Bureau issued a final rule raising the loan-volume coverage thresholds for financial institutions reporting data under the Home Mortgage Reporting Act.

The Consumer Financial Protection Bureau issued a final rule raising the loan-volume coverage thresholds for financial institutions reporting data under the Home Mortgage Reporting Act.

The final rule, amending Regulation C, increases the permanent threshold for collecting and reporting data about closed-end mortgage loans from 25 to 100 loans effective July 1, 2020.

It will also amend Regulation C to increase the permanent threshold for collecting and reporting data about open-end lines of credit from 100 to 200, effective January 1, 2022, when the current temporary threshold of 500 of open-end lines of credit expires. 

In October 2019, the CFPB extended the temporary open-end threshold until January 1, 2022. Without the final rule, the open-end threshold would have reverted to 100 open-end lines of credit upon the expiration of the temporary threshold.

The bureau recognizes the operational challenges confronted by institutions due to the current COVID-19 pandemic. The agency said the rule will reduce regulatory burden on smaller institutions to help those institutions to focus on responding to consumers in need now and in the longer term.

HMDA and its implementing regulation require certain financial institutions to report data about mortgage loan applications, originations and their purchases. The data serve HMDA’s purposes, which are to help determine whether financial institutions are serving the housing needs of their communities, to assist public officials in distributing public-sector investment so as to attract private investment to areas where it is needed, and to assist in identifying possible discriminatory lending patterns and enforcing antidiscrimination statutes.

Fredrikson & Byron Law