Comments on HMDA thresholds, remittances due in June

June 4, 2019

Comments on proposals on Home Mortgage Disclosure Act reporting thresholds, loans and lines of credit to members and remittances are due in the month of June. A complete list of upcoming deadlines can be found on CUNA’s advocacy action page.

The Consumer Financial Protection Bureau’s (CFPB) HMDA proposal contains two alternatives to amend Regulation C to increase the threshold for reporting data about closed-end mortgage loans so that institutions originating fewer than either 50 closed-end mortgage loans, or alternatively 100 closed-end mortgage loans, in either of the two preceding calendar years would not have to report such data as of Jan. 1, 2020.

It would also adjust the threshold for reporting data about open-end lines of credit by extending to January 1, 2022, the current temporary threshold of 500 open-end lines of credit and setting the threshold at 200 open-end lines of credit upon the expiration of the proposed extension of the temporary threshold.

Comments are due June 12.

Other comment deadlines this month include:

  • June 24: NCUA’s advance notice of proposed rulemaking on ways to improve regulations limiting a credit union official's and employee's compensation in connection with loans to members and lines of credit to members. NCUA is particularly interested in thoughts on how it can provide flexibility with respect to senior executive compensation plans that incorporate lending as part of a broad and balanced set of organizational goals and performance measures;
  • June 28: CFPB request for information (RFI) on potential regulatory changes to its remittances rule. The RFI seeks information and evidence that may inform possible changes to the Rule that would not eliminate, but would mitigate the effects of the expiration of a statutory exception for certain financial institutions; and
  • June 28: CFPB RFI on remittances rule coverage and temporary fee estimates safe harbor. The CFPB seeks information that may inform possible changes that would not eliminate, but would mitigate the effects of the expiration of an exception from the rule for certain financial institutions. The CFPB also seeks information related to the rule's coverage, including whether to change a safe harbor that determines who must comply, and whether a small financial institution exception may be appropriate.