As we have previously reported, in October 2015, the Consumer Financial Protection Bureau (CFPB) issued a sweeping final rule ("2015 Final Rule") to amend Regulation C, which implements the Home Mortgage Disclosure Act (HMDA). The bulk of the 2015 Final Rule will become effective on January 1, 2018. With the effective date drawing nearer, the CFPB has proposed an amendment to the 2015 Final Rule, which would, for calendar years 2018 and 2019, increase the threshold for collecting and reporting data on home equity lines of credit (HELOCs). Specifically, the proposed amendment would require only those institutions originating 500 or more HELOCs in each of the two preceding years to collect and report HMDA data on HELOC originations and applications. Additionally, the CFPB has recently released several new and updated resources for HMDA filers, including an illustrative guide to assist filers in preparing loan/application registers for data collected in 2018 and beyond. This alert summarizes these recent developments.
Read our client alert.
Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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