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Regulation C (HMDA) Amendments

Published on Wednesday, September 13, 2017 in Client and Friends Memo, HMDA

In the September 13, 2017, issue of the Federal Register (82 FR 43088, click here) the CFPB published a final rule amending its 2015 HMDA (Regulation C) Final Rule to: (i) make technical corrections and clarify certain requirements; (ii) temporarily increase the threshold for collecting and reporting data about open-end lines of credit for a period of two years so that financial institutions originating fewer than 500 open-end lines of credit in either of the preceding two years would not be required to begin collecting such data until January 1, 2020; and (iii) adopt a new reporting exclusion.

 The following summary of the final rule is from the preamble to the final rule and is edited for clarity and brevity.

  • The final rule is effective on January 1, 2018, except that the amendments to §1003.5 in amendatory instruction 8, the amendments to §1003.6 in amendatory instruction 9, and the amendments to supplement I to part 1003 in amendatory instruction 10 are effective on January 1, 2019; and the amendments to §1003.2 in amendatory instruction 11, the amendments to §1003.3 in amendatory instruction 12, the amendments to §1003.5 in amendatory instruction 13, the amendments to §1003.6 in amendatory instruction 14, and the amendments to supplement I to part 1003 in amendatory instruction 15 are effective on January 1, 2020. (See pages 43145 and 46 for these amendatory instructions.)

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