CFPB Proposes Higher HMDA Thresholds

May 03, 2019
The Consumer Financial Protection Bureau proposed raising the coverage thresholds for collecting and reporting data about closed-end mortgage loans and open-end lines of credit under the Home Mortgage Disclosure Act.

The proposal would provide relief to smaller lenders from HMDA reporting requirements and clarify ICBA-advocated HMDA exemptions contained in the S. 2155 regulatory relief law.

The CFPB is proposing raising the coverage threshold for closed-end mortgage loans from 25 to either 50 or 100 loans. For open-end lines of credit, the proposal would extend for another two years the current temporary coverage threshold of 500 open-end lines of credit. Once that temporary extension expires, it would permanently set the threshold at 200.

The CFPB also issued an advance notice of proposed rulemaking seeking comments on the costs and benefits of collecting and reporting HMDA data.

Under S. 2155, banks with “satisfactory” CRA ratings that originate fewer than 500 closed-end mortgage loans or 500 open-ended lines of credit are exempt from HMDA data fields added by the bureau in 2015. Lenders are still required to collect and report the data fields in place prior to the 2015 rule.

ICBA has been working to increase these minimum reporting thresholds and will submit comments advocating for the higher thresholds contained in the proposal.

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