HMDA Final Rule Released Today

Part of the HMDA proposals were finalized today, though they say they will be issuing another rule to address the permanent threshold changes. So, it seems that this is (at least) part 1 of 2, though the rule is still 239 pages long. Happy reading...

https://files.consumerfinance.gov/f/documents/cfpb_hmda_final-rule-2019.pdf

Happy here in WA!

Happy for the open-end threshold (500) extension? I think many more will be happy once the other final rule is released later this year, which they referenced in this release.

It's 500 originated open end lines of credit, right? It still doesn't impact my bank but had hopes it would.

Yes, the 500 open-end line threshold was extended for two years, but your hopes can remain in tact as the CFPB will still be addressing possible permanent threshold changes for both open-end and closed-end. The comment period just closed on Tuesday (10/15/19), so it will be interesting to see how quickly they get a final rule out.

So what I am reading for closed end loans, the bureau has changed to increase the current 25-loan coverage threshold for reporting data about closed-end mortgage loans so that institutions originating fewer than either 50 closed-end mortgage loans, or alternatively 100 closed-end mortgage loans, in either of the two preceding calendar years would not have to report such data. Have they finalized this? Is it 50 or 100? And does this mean that if we originated 40 loans in 2017 and 30 loans in 2018 and so far in 2019 have 25 we will not have to report by February 2020 for our 2019 loans?

This has not yet been finalized, so there is no telling what the new threshold will be - if it is, in fact, changed. That said, my bet is on 50 (because I am a pessimist at heart)... but that is purely a guess.

The original proposal had a tentative effective date as of 1/1/2020, so I believe 2019 data will still need to be submitted. (Anything could happen with the final rule, but I would absolutely plan to submit the 2019 data, as an effective date of 1/1/2020 would typically mean you don't have to collect and report 2020 data.)