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Comments due on CFPB proposal on HMDA reporting threshold for HELOCs

07/31/2017
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The Consumer Financial Protection Bureau (CFPB) announced Friday afternoon a proposal on HMDA reporting requirements for banks and credit unions that issue home-equity lines of credit. Under rules that are scheduled to take effect in January 2018, financial institutions are generally required under the Home Mortgage Disclosure Act (HMDA) to report home-equity lines of credit if they made 100 such loans in each of the last two years. The new proposal would increase that threshold to 500 loans through calendar years 2018 and 2019 so that the Bureau can consider whether to make a permanent adjustment.

The Bureau said that it has heard increasing concerns from community banks and credit unions that the challenges and costs of reporting open-end lending may be greater than the Bureau had estimated when adopting the 100-loan threshold. The CFPB estimates that the temporary 500-loan threshold would still capture about three-quarters of the home-equity lending market, down from about 88 percent at the 100-loan threshold. Comments will be accepted through July 31, 2017.

UPDATE: Published in the July 20, 2017, Federal Register.

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