Home Mortgage Disclosure Act Rule Implementation Issued

On August 31, 2018, the Bureau of Consumer Financial Protection (Bureau) issued an interpretive and procedural rule to implement and clarify changes made by section 104(a) of the Economic Growth, Regulatory Relief, and Consumer Protection Act (the Act) to the Home Mortgage Disclosure Act (HMDA). The rule is effective immediately upon publication in the Federal Register.

If you follow this link you can gain access to the Bureau’s executive summary which provides an overview of the 2018 HMDA Interpretive and Procedural Rule (2018 Rule).

The Act provides that an insured depository institution or insured credit union does not need to collect or report certain data with respect to closed-end mortgage loans if it originated fewer than 500 closed-end mortgage loans in each of the two preceding calendar years. Similarly, the Act provides that an insured depository institution or insured credit union does not need to collect or report certain data with respect to open-end lines of credit if it originated fewer than 500 open-end lines of credit in each of the two preceding calendar years. The Act further provides that these partial exemptions are unavailable to an insured depository institution if it received a rating of “needs to improve record of meeting community credit needs” during each of its two most recent Community Reinvestment Act (CRA) examinations or a rating of “substantial noncompliance in meeting community credit needs” on its most recent CRA examination.

Please let ABS know if we can help you comply with the new HMDA requirements.