BCFP updates HMDA compliance guide w/ S. 2155 changes

November 1, 2018

The Bureau of Consumer Financial Protection has updated its small entity compliance guide for the Home Mortgage Disclosure Act (HMDA) to reflect changes in the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) and the bureau’s August interpretive rule.

CUNA has urged the bureau to move quickly in implementing the changes required by S. 2155 as well as provide additional regulatory relief to credit unions.

S. 2155 exempts insured financial institutions from reporting certain data with respect to:

  • Closed-closed end mortgage loans if the institution originated fewer than 500 such loans in each of the two preceding calendar years; and
  • Open-end lines of credit if it originated fewer than 500 such lines of credit in each of the two preceding calendar years.

The bureau’s Fall 2018 rulemaking agenda indicates it intends to continue necessary actions to implement HMDA relief, and that a proposed rule is expected in Spring 2019 to consider substantive changes to HMDA.