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HMDA Open-End Credit Threshold Maintained through 2021

On October 10, 2019, the CFPB released a final rule (not yet published in the Federal Register) extending the current 500 open-end credit threshold until January 1, 2022. This new rule is effective on January 1, 2020.

In addition to the rule above, the Bureau has issued an Executive Summary and an “unofficial, informal” redline of the changes to the Regulation.

If you recall, back in August 2017 the threshold was increased from 100 to 500 for collecting and reporting open‐end lines of credit for a two‐year period which expires at the end of 2019; that threshold was increased from 25 to 100 back in October 2015. The 500-loan threshold was set to revert back to 100 starting in January.

According to the preamble:

“… the Bureau intends to address in a separate final rule the changes it proposed to the permanent coverage thresholds for open-end lines of credit and closed-end mortgage loans. In the interim, extending the current temporary increase in the open-end coverage threshold for an additional two years will allow the Bureau to consider fully the appropriate level for the permanent open-end coverage threshold for data collected beginning January 1, 2022, after reviewing additional comments relating to that aspect of the proposal.”

It looks like we can expect some further clarifications within the next two years.

This release also codifies the procedural rules released in 2018 regarding the ability of institutions taking advantage of partial exemptions to optionally report exempt data points (TCA Special Release Volume 15, Issue 17) and also addresses certain additional interpretations relating to those partial exemptions not specifically addressed (i.e., determining whether a partial exemption applies to a transaction after a merger or acquisition).

HMDA is a constantly evolving area and TCA is A Better Way of navigating the twists and turns. Contact us at (800) 9347347 or by email at [email protected] for all your compliance needs.

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