BCFP Updates HMDA Compliance Guide with S. 2155 Changes

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The Bureau of Consumer Financial Protection (BCFP) 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.

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

  • Closed-end mortgage loans if the institution originated fewer than 500 such loans in each of the two preceding calendar years
  • 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.

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