All in HMDA

2020 HMDA Exemption Threshold

Adam Witmer
HMDA, Regulatory Update

On December 20, 2019, the CFPB adjusted the HMDA exemption threshold from $46 million to $47 million.  The adjustment is based on the 1.6 percent increase in the average of the CPI-W for the 12-month period ending in November 2019 (down from 2.6 last in 2018). Therefore, banks, savings associations, and credit unions with assets of $47 million or less as of Dec. 31, 2019, are exempt from collecting data in 2020.

UPDATE on HMDA Changes! - CFPB Gives Timetable for Final Rules

Adam Witmer
HMDA, Regulatory Update

As the new year is quickly approaching, we have continued to receive a number of questions regarding a potential final HMDA rule that would (possibly) increase the thresholds for reporting of both closed-end and open-end loans.  This, of course, could provide significant relief to HMDA reporters, especially those reporters who have fairly small HMDA LARs.

As the CFPM released their Fall regulatory agenda this week (11/20/19), the Bureau provided us with a bit of insight into their plans for two potential new HMDA rules that could provide significant relief…

CFPB Issues HMDA Final Rule to Implement Partial Exemption

Adam Witmer
HMDA

On October 10, 2019 the Consumer Financial Protection Bureau (CFPB) issued a rule which finalizes some parts of its May 2019 Notice of Proposed Rulemaking that we previously reported on. This new final rule extends for two years the current temporary threshold for collecting and reporting data about open-end lines of credit under HMDA. The rule also clarifies partial exemptions from certain HMDA requirements which Congress added in the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA).

HMDA Changes Coming & Comments Due

Adam Witmer
HMDA, Regulatory Update

We received a question this week about when to expect more HMDA changes.  That’s right, more HMDA changes are on the horizon, but we really don’t know when to expect them.  As we reported back in May of 2019, the CFPB has issued two things that could result in more HMDA changes: 1) a Notice of Proposed Rulemaking as well as 2) an Advance Notice of Proposed Rulemaking. This article provides a summary of the possible changes, what to look for, and a reminder that comments on both potential changes are due on October 15, 2019.

HMDA Temporary Financing for Bridge Loans

HMDA Temporary Financing for Bridge Loans

Adam Witmer
HMDA

In this Compliance Clip (video), Adam talks about HMDA applicability for bridge loans under the new temporary financing rules. While these rules have been around for a bit now, we are still seeing some confusion with reporting (or not) bridge loans as it relates to HMDA.

CFPB Reopens Second HMDA Comment Period

Adam Witmer
HMDA, Regulatory Update

As we reported last month, the CFPB decided this summer to reopen two comment periods relating to the Home Mortgage Disclosure Act (HMDA). On July 31, 2019, the CFPB announced the reopening of the comment period for specific aspects of the proposed rule published by the Bureau in the Federal Register on May 13, 2019 (84 FR 20972) (May 2019 Proposal). In their announcement, the Bureau explained that one of the main reasons for reopening the original 30-day comment period is to allow commenters to be able to

HMDA Income for Cosigners (Video)

HMDA Income for Cosigners (Video)

Adam Witmer
HMDA

In this Compliance Clip (video), Adam explains how to report income under the Home Mortgage Disclosure Act in relationship to cosigners. The question we have this:

Question: A loan has one borrower and a co-signer. Do I report the income of just the borrower, or do I report the income of the co-signer since we wouldn’t do the loan with just the borrower?

The answer to this come from 1003.4(a)(10) of Regulation C. In this video, Adam breaks down the different HMDA requirements for reporting income as it relates to co-signers and breaks down a few key phrases as well as the applicable commentary to Regulation C.

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