Are You Aware of HMDA Reporting Thresholds?

by Bill Dolan, CMB, AMP

The CFPB in April, 2020, issued a final Home Mortgage Disclosure Act (HMDA) rule to increase the threshold to report closed-end mortgage loans from 25 to 100 originated loans in each year of the prior two tears, and to increase the permanent threshold to report dwelling-secured open-end lines of credit from 100 to 200 originated lines in each of the prior two years. The new closed-end threshold was effective July 1, 2020. The new permanent open-end lines of credit threshold is effective January 1, 2022, as a temporary threshold of 500 originated open-end lines of credit in each of the prior two years is in effect through 2021. THE CFPB also issued an executive summary of the final rule, an unofficial redline of the changes to Regulation C along with other helpful materials.

With the end of the third quarter upon us, now is a very good time to review where your financial institution stands with regards to the reporting thresholds – especially if your bank or credit union exceeds the thresholds in 2020. If you are on pace to once again, exceed the thresholds in 2021, you need to begin planning on how your institution is going to collect data in 2022 that would be reported by March 1, 2023.

Let SCA take the guesswork out of the process for you. Please reach out and contact Bill Dolan, Director for a free consultation regarding SCA HMDA LAR review services that we are currently scheduling for 2022. You may also check out our website at www.scapartnering.com to see the other services that SCA offers.