How is HMDA institutional coverage being adjusted?

Compliance > Regulation C - HMDA > 2018 Provisions
Q:  How is HMDA institutional coverage being adjusted?
 
A:  Effective January 1, 2018, the 2015 HMDA Rule adopts a uniform loan-volume threshold for all financial institutions.
 
Beginning in 2018, a financial institution will be subject to Regulation C if it originated at least 25 covered closed-end mortgage loans in each of the two preceding years or at least 100 covered open-end lines of credit in each of the two preceding calendar years, and it meets other applicable coverage requirements. For depository financial institution coverage, the 2015 HMDA Rule maintains current Regulation C’s asset-size threshold, location test, federally related test, and loan activity test. For nondepository financial institutions, the 2015 HMDA Rule retains the current location test. A nondepository financial institution is subject to Regulation C, effective January 1, 2018, if it originated at least 25 covered closed-end mortgage loans or at least 100 covered open-end lines of credit in each of the two preceding calendar and meets the location test. 12 CFR 1003.2(g)(1), (2).
 
 
ADDITIONAL INFORMATION:
This information was obtained from the CFPB’s Home Mortgage disclosure (Regulation C) Small Entity Compliance Guide.  https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201512_cfpb_hmda_small-entity-compliance-guide.pdf
 

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