On April 17, 2020, we alerted you to a HMDA Final Rule that will raise the closed-end threshold to 100, effective July 1, 2020, and the open-end threshold to 200, effective January 1, 2022.
What this Means
While this is obviously good news for some of you, it doesn’t come without additional compliance implications. If you’re affected by either of these changes, you are going to need to retrain your lenders.
Even if you are no longer subject to HMDA data collection/reporting, you ARE still subject to Regulation B.
While these changes may result in you no longer collecting race, sex and ethnicity information for HMDA (dwelling-secured applications for loans (and/or lines) for home purchase, home improvement, refinance or consumer home equity), you will still need to collect Government Monitoring Information (GMI) under Regulation B.
Regulation B’s collection requirement only applies to applications primarily for the purchase or refinancing of an applicant’s primary residence (1-4 family dwelling) that will be secured by that same dwelling.
It’s pretty easy to see that your lenders are going to need to be retrained if these changes affect your institution. We can help! First, if you need more information on these HMDA Changes, we have a webinar, “NEW! 2020 HMDA Final Rule”, which is available NOW On-Demand. Second, we will be hosting a webinar, “Collecting GMI Under Regulation B”, on June 3, 2020. This webinar will walk you through the ins and outs of transitioning from HMDA to Regulation B, collection forms, Fair Housing logs (for OCC Banks) and more!
Published
2020/05/15
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