Comments on two Consumer Financial Protection Bureau (CFPB) items regarding the Home Mortgage Disclosure Act (HMDA) are due in October, a proposal on reporting thresholds and an advance notice of proposed rulemaking (ANPR) on data points. Both are due Oct. 15.
The comment period on HMDA reporting thresholds proposal was re-opened in July to align the two deadlines.
The proposal calls for increasing HMDA reporting thresholds for closed-end mortgages to 50 or 100 loans (up from the current 25) and extending the current temporary thresholds of 500 open-end lines of credit until Jan. 1, 2022.
CUNA filed initial comments on HMDA thresholds in June, recommended the CFPB increase its HMDA reporting threshold to 500 closed-end mortgage loans in each of the prior two calendar years, reducing the compliance burdens for more than 1,500 credit unions.
The ANPR on data points seeks comments on:
Also due in October are comments on the Department of Housing and Urban Development’s (HUD) implementation of its disparate impact standard.
This rule proposes to amend HUD's interpretation of the Fair Housing Act's disparate impact standard to better reflect the Supreme Court's 2015 ruling in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc. and to provide clarification regarding the application of the standard to State laws governing the business of insurance.
Comments on the HUD proposal are due Oct. 10.