CFPB extends HMDA open-end line of credit threshold to 2022

October 10, 2019

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

“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,” said Alexander Monterrubio, CUNA senior director of advocacy and counsel.

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.

It also incorporates into Regulation C the clarifications from the Bureau’s August 2018 interpretive and procedural rule for partial exemptions under the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155).

Thursday’s rule finalizes aspects of the May 2019 proposed rule that would raise the permanent coverage thresholds for closed-end mortgage loans and open-end lines of credit. 

On Friday, National Credit Union Administration Chairman Rodney E. Hood welcomed the final rule. “This is positive news for small credit unions,” Hood said. “Regulators need to stay mindful of the reporting burdens we place on smaller institutions, and we should always work to tailor rules appropriately. This will allow small credit unions to focus resources on serving their member-owners, not burdensome government regulations.”

On July 31 the CFPB reopened the comment period until Oct. 15 for aspects of the May 2019 proposal related to raising the permanent coverage thresholds.

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.