As previously reported, in April 2020 the CFPB released a final rule to increase the threshold to report closed-end mortgage loans under the Home Mortgage Disclosure Act (HMDA) from 25 to 100 originated loans in each of the prior two years, and to increase the permanent threshold to report dwelling-secured open-end lines of credit under HMDA from 100 to 200 originated lines in each of the prior two years. The final rule was published in the May 12, 2020 Federal Register.

The CFPB recently issued an updated version of the HMDA Small Entity Compliance Guide to reflect the changes in the thresholds. While the CFPB is required by law to issue guides to help small entities comply with new regulations, the HMDA Small Entity Compliance Guide also is a resource for larger entities.