Changes to HMDA’s Closed-End Loan Threshold

In September, a Federal District Court invalidated the CFPB’s increase of HMDA’s closed-end loan reporting threshold from 25 to 100, which occurred back in 2020. Since then, we have just been patiently waiting for the CFPB to chime in, and they did it earlier this week.

This could have huge implications for your institution as it appears banks will need to be ready to go by January 1, 2023!! But there are still a lot of unanswered questions.

David explains more in the video.

 

HMDA Resources!

 

Many of you've heard that the CFPB is lowering the threshold for HMDA from 100 down to 25. In other words, if you originated 25 or more closed-in loans subject to HMDA in the last two years, you will be subject to HMDA beginning in 2023. Now, when they changed this back in 2020, they said there were about 1,700 institutions that were exempt from HMDA because of this.

So, in other words, probably about 1,700 institutions are now going to have to flip the switch to start doing HMDA reporting again. There are lots of questions. There's a lot of ambiguity in the announcement by the CFPB. We are getting to the bottom of these. We're finding out what you'll need to do. You've got three short weeks to get ready to do HMDA again. That's why we're offering a one-hour webinar. Join me, and we'll get your questions answered. We'll give you a roadmap on how to get ready and flip on those switches for HMDA reporting again. 

Published
2022/12/9
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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