Do I understand The Regulatory Relief law correctly:

Before the law was enacted, it was only the lines of credit that were exempt from reporting if fewer than 500 open end lines of credit had been opened in the preceding two years. This exemption was allowed in 2018 and 2019 only.

With the Regulatory Relief, it appears that the exemption from reporting most of the expanded information is permanent, not just for 2018 and 2019. Is this correct?

Also - if I read this correctly BOTH of the two preceding years must show reportable closed or open-end loans/lines less than 500 to be exempt. If ONE of the two years, exceeds 500 reportable, then the financial institution must report the expanded information. Is this also correct?

Correct. Originally, lines of credit were set set at 100. Below that, you didn't report them at all. The 500 lines threshold was passed in August 2017 and only for a 2 year "trial". It expires in 2020.



The "Small Filer" exemption says 500 loans or lines. It is permanent but it is a moot point for lines, for now (until 2020). We don't know what the CFPB plans to do with lines of credit in 2020 and beyond. Will the temporary exemption of 500 continue? Will it released so the regulation will go back to 100-499 (small filer) and 500+ = large filer?


You are correct. If you hit 500 or more in any one of the previous two years, you don't qualify for the "small filer" exemption.

Thank you David!