CFPB Issues HMDA Final Rule
The CFPB issued a Final Rule that addresses portions of their May 2019 Notice of Proposed Rulemaking. That particular Proposal is not to be confused with the Advanced Notice of Proposed Rulemaking that was also issued in May 2019. Both have comment deadlines of October 15th. Our September 16th blog helps sort these out a bit.
What the Final Rule does:
1. Incorporates the Small Filer exemptions, granted by the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA), into the HMDA regulation (12 CFR 1003);
2. Extends the temporary threshold for open-end lines of credit (currently 500) until January 1, 2022. In other words, the open-end lines threshold for determining if an institution must collect/report HMDA data for open-end lines in 2020 and/or 2021 will be 500.
These changes are effective January 1, 2020.
The Final Rule does NOT address the proposed permanent threshold changes for either closed-end or open-end credit. The comment period for these proposed changes remains open until October 15th. The CFPB will address these with a separate Final Rule later in 2020.
Published
2019/10/11
Amy Kudlacek
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!