HMDA Regulation C Final Rule Amends Permanent Institutional and Transactional Coverage Thresholds

In Client and Friends Memos by BMG Memorandum

In the May 12, 2020, Federal Register (85 FR 28364, click here), the Consumer Financial Protection Bureau (CFPB) issued a final rule amending Regulation C (12 CFR part 1003), which implements the Home Mortgage Disclosure Act (HMDA).

The final rule permanently increases the institutional and transactional coverage thresholds for reporting data about closed-end mortgage loans from 25 to 100 closed-end mortgage loans effective July 1, 2020. (See the amended §§1003.2(g)(1)(v)(A) and (g)(2)(ii)(A) for the institutional coverage threshold for depository and nondepository financial institutions, respectively, and the amended §1003.3(c)(11) for the transactional coverage threshold attached to this memorandum.)

The final rule also amends §1003.3(c)(11) and comment 3(c)(11)–2 so that institutions have the option to report closed-end data collected in 2020 if they (1) meet the definition of financial institution as of January 1, 2020 but are newly excluded on July 1, 2020 by the increase in the closed-end threshold, and (2) report closed-end data for the full calendar year.

 

Full Memorandum