CFPB Proposes to Increase the HELOC Volume Threshold for HMDA

As I’m sure you are well aware, under the new HMDA rules, a bank (that meets the asset threshold test, Metropolitan Statistical Area (MSA) test, and originated at least one home purchase/refinance loan secured by a 1st lien on a 1-4 family dwelling), is subject to HMDA data collection in 2018, IF in the prior two calendar years (2017 and 2016) the bank originated at least:

  1. 25 closed-end dwelling secured loans; OR,
  2. 100 open-end lines of credit secured by a dwelling.

There may be some good news on the horizon for some of you!  Due to concerns that the open-end transaction coverage threshold (100) is too low, the CFPB has proposed to temporarily increase that threshold to 500 for two years (calendar years 2018 and 2019).  This means that financial institutions originating fewer than 500 open-end lines of credit in either of the preceding two years would not be required to collect and report data with respect to open-end credit.

To put that in plain English:

You’re required to report 2018 open-end credit if you originated 500 or more open-end lines in both 2016 and 2017.  If you originate less than 500 open-end lines in 2017 you won’t have to report open-end lines in 2018 or 2019.  That’s really all you need to know for now.  Beyond that we’ll take the wait and see approach.  Stay tuned!

If you’re looking for training on the upcoming HMDA changes, we have multiple webinars and live events coming up.  Whether you need a full overview or just training on specific areas, we’ve got you covered.  Check out our store for more information.

Published
2017/08/03
Deb Irving
David Dickinson

David Dickinson

David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.

He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.

David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.

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