CUNA responds to CFPB's extension of HMDA open-end line of credit threshold

October 10, 2019


October 10, 2019   

Washington, DC    


Lauren Williams        
CUNA Communications        

“While credit unions appreciate the CFPB extending the increased HMDA reporting threshold for open-end lines of credit, we strongly recommend the Bureau take action to make the 500-line threshold permanent to reduce the regulatory burden credit unions face, allowing them to confidently extend credit to consumers across the country.” 

- Alexander Monterrubio, Senior Director of Advocacy & Counsel for the Credit Union National Association. 


The Consumer Financial Protection Bureau (CFPB) issued a final rule today extending the 500 open-ended line of credit Home Mortgage Disclosure Act (HMDA) reporting threshold for an additional two years, to Jan. 1, 2022. Credit Union National Association (CUNA) is supportive of the CFPB maintaining a 500 line-of-credit threshold but has called for the CFPB to make the threshold permanent. 

Specifically, the final rule extends for another two years the current temporary coverage threshold of 500 open-end lines of credit. For data collection years 2020 and 2021, financial institutions that originated fewer than 500 open-end lines of credit in either of the two preceding calendar years will not need to collect and report data with respect to open-end lines of credit. 

CUNA has urged credit unions to comment on that proposal before the Oct. 15 deadline. According to the CFPB, it intends to issue a separate final rule in 2020 addressing these thresholds. 


About CUNA:          
Credit Union National Association (CUNA) is the only national association that advocates on behalf of all of America’s credit unions, which are owned by 115 million consumer members. CUNA, along with its network of affiliated state credit union leagues, delivers unwavering advocacy, continuous professional growth and operational confidence to protect the best interests of all credit unions. For more information about CUNA, visit To find your nearest credit union, visit