The Consumer Financial Protection Bureau (CFPB) recently posted on its website updated versions of guidance in connection with the revisions to the Home Mortgage Disclosure Act (HMDA) rules that become effective on January 1, 2018.
The CFPB updated the key dates timeline, 2018 HMDA institutional coverage chart and 2018 HMDA transactional coverage chart to reflect the temporary increase in the threshold to report home equity lines of credit (HELOCs). In the original version of the revised HMDA rules, an institution that made at least 100 HELOCs in each of the prior two years would need to report HELOCs for the current reporting year. For example, an institution that made at least 100 HELOCs in each of 2016 and 2017 would have to collect and report data on HELOCs for 2018. As previously reported, the CFPB temporarily increased the threshold from 100 to 500 HELOCs for 2018 and 2019, and will assess the appropriate reporting threshold to be implemented in 2020.