The Federal Financial Institutions Examination Council (FFIEC) recently issued the 2020 edition of the Guide to HMDA Reporting: Getting It Right! (2020 Guide).
As previously reported, in October 2019 the CFPB issued a Home Mortgage Disclosure Act (HMDA) final rule that:
- Continues until January 1, 2022 the temporary volume threshold that triggers reporting of open-end, dwelling-secured lines of credit of at least 500 originated lines of credit in each of the prior two calendar years.
- Incorporates into Regulation C the interpretative and procedural rule previously issued by the CFPB to implement the partial exemption from HMDA reporting for smaller volume bank and credit union lenders adopted in the Economic Recovery, Regulatory Relief, and Consumer Protection Act (Growth Act).
The 2020 Guide reflects these changes. The CFPB still needs to finalize the permanent threshold for reporting open-end, dwelling-secured lines of credit, as well as the threshold for reporting closed-end mortgage loans. According to the CFPB’s fall rulemaking agenda, final action on both thresholds is expected in March 2020.
