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CFPB Amends HMDA Reporting Requirements for HELOCs

Tue 26 Sep, 2017  /  by McIntyre & Lemon  /   Client Alerts

09/26/17 – The Consumer Financial Protection Bureau (CFPB) has issued a rule amending the 2015 updates to the Home Mortgage Disclosure Act (HMDA).

The CFPB has temporarily changed reporting requirements for banks and credit unions that issue home-equity lines of credit (HELOCs). Additionally, the CFPB has clarified the information that financial institutions are required to collect and report about their mortgage lending.

The CFPB updated the HMDA regulation in 2015 to improve the quality and type of data reported by financial institutions. Most of the updated requirements take effect in January 2018, and the industry is working to bring operations into compliance.

Under the original rules that are scheduled to take effect in January 2018, financial institutions would have been required to report HELOCs if they made 100 of those loans in each of the last two years. The amended final rule has temporarily increased that threshold to 500 loans through calendar years 2018 and 2019. The CFPB has yet to decide whether or not to make the reduced threshold a permanent adjustment.

The final rule also contains a number of clarifications, technical corrections, and minor changes to the HMDA regulation. These include clarifying certain key terms, such as “temporary financing” and “automated underwriting system.” The changes will also establish transition rules for reporting certain loans purchased by financial institutions. Another change will facilitate reporting the census tract of a property using a geocoding tool that will be provided on the Bureau’s website.

CFPB Press Release; Final Rule.