May 13, 2019

CFPB is proposing two alternatives to amend Regulation C to increase the threshold for reporting data about closed-end mortgage loans. The proposal specifies 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 January 01, 2020. The proposed rule would also revise the information collection requirements in Regulation C. Comments on the proposed rule must be received on or before June 12, 2019, except that comments on the proposed revisions to the information collection requirements must be received on or before July 12, 2019.

The proposed rule would adjust the threshold for reporting data about open-end lines of credit by extending to January 01, 2022, the current temporary threshold of 500 open-end lines of credit and setting the threshold at 200 open-end lines of credit on the expiration of the proposed extension of the temporary threshold. The proposed rule also implements the partial exemptions from the Home Mortgage Disclosure Act (HMDA) requirements that the Economic Growth, Regulatory Relief, and Consumer Protection (EGRRCP) Act recently added to HMDA. In August 2018, CFPB had issued an interpretive and procedural rule to implement and clarify the EGRRCP Act amendments to HMDA (2018 HMDA Rule). The proposed rule incorporates into Regulation C these interpretations and procedures, with minor adjustments, by adding new § 1003.3(d) related to the partial exemptions and making various amendments to the data compilation requirements in § 1003.4.

The proposed rule further implements the EGRRCP Act by addressing certain additional interpretive issues related to the partial exemptions that the 2018 HMDA Rule did not specifically address, such as how to determine whether a partial exemption applies to a transaction after a merger or acquisition. With respect to the proposed revisions to the information collection requirements, the proposed rule would adjust the institutional and transactional coverage thresholds of Regulation C. The proposal would also implement the new, separate EGRRCP Act partial exemptions that apply to some HMDA reporting requirements. 

 

Related Link: Federal Register Notice

Comment Due Date: June 12, 2019 and July 12, 2019 (Information Collection)

Keywords: Americas, US, Banking, Securities, HMDA, EGRRCP Act, Reporting, Regulation C, Information Collection, Disclosures, Home Mortgage, CFPB

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