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.
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