2018 HMDA- Rule on Collecting/Reporting HELOC Data

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Question:

We are a credit union and want to make sure that I'm reading this right concerning HELOCs. Under the rule financial institutions originating 100 or more HELOCs will file 2020 HELOC data, but if we originate fewer than 500 in 2018 or 2019 we would not be required to begin collecting and reporting HELOC data until January, 1 2020. As a credit union do we fall under this rule as well?

Answer:

If your credit union meets the definition of "Depository financial institution" in Regulation C § 1003.2(g)(1), you fall under the same rules as other depository financial institutions. For 2018 and 2019, you have to have originated either 25 closed-end mortgage loans that aren't excluded under § 1003.3(c)(1) through (10) or § 1003.3(c)(13) in each of the two preceding calendar years (during 2016 and 2017 to file in 2018, and during 2017 and 2018 to file in 2019), OR, in each of the two preceding calendar years, originated at least 500 open-end lines of credit [HELOCs] that are not excluded under § 1003.3(c)(1) through (10). In 2020, under the current regulation, "500" will change to "100."

To determine whether you file on closed-end or open-end loans in 2018, you look at your originations of those loans in 2016 and 2017. To determine whether you file on closed-end or open-end loans in 2019, you look at your originations of those loans in 2017 and 2018. For 2020 filing, you look at your originations in the previous two years, 2018 and 2019.