Now Does Your Bank Need to Collect and Report Open-End Credit for HMDA?
October 5, 2021REGISTER NOW
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Now Does Your Bank Need to Collect and Report Open-End Credit for HMDA? has been submitted to ABA Professional Certifications for CE credit review and is pending approval. Once we receive notification of the credit approval, we will notify attendees.
On April 16, 2020 the Consumer Financial Protection Bureau (CFPB) published a final rule amending Regulation C to amend the thresholds for reporting data about open-end lines of credit. The previous threshold of 500 lines of credit has been lowered to 200 effective January 1, 2022.
If an institution has originated:
- Fewer than 200 open-end lines of credit in each of the two years in the calculation period it continues to be exempt from reporting open-end credit in its loan application register (LAR).
- 200 or more lines of credit in each of the two years in the calculation period then it must collect and report data on its open-end lines of credit on its LAR, beginning January 1, 2022.
For the first decades of HMDA, Regulation C only required collection and reporting for closed-end loans.
- In 2015, collection and reporting became mandatory for open- lines of credit.
- The final rule required collection and reporting of open-end data if more than 100 open-end lines had been collection in either of the prior two years.
- Quickly a temporary rule was enacted that elevated the threshold to 500 lines of credit until January 1, 2020.
- A 2019 Final Rule extended the 500 line threshold to January 1, 2022.
The CFPB estimates that approximately 333 financial institutions originated at least 500 open-end lines of credit in each of the two preceding years, and approximately 613 financial institutions originated at least 200 open-end lines of credit in each of the two preceding years. The 333 institutions have been collecting, and will continue to be required to collect, HMDA data for open-end lines of credit. If your institution is one of the 280 financial institutions newly covered by the rule it will need to begin collecting data on open-end lines of credit on January 1, 2022.
If your institution is subject to requirements to report data regarding open-end lines of credit, then this two-hour webinar provides exactly what you need to know. Participants receive a detailed manual that serves as a handbook long after the program is completed.
The program explores:
- Which institutions are covered by HMDA and Regulation C;
- Which loans are covered by or exempt from HMDA;
- Whether a financial institution can exempt open-end lines of credit now or in the future;
- The proper method of calculating the 200 open-end lines of credit threshold;
- When open-end lines of credit first became HMDA reportable and history of the exemption;
- How the EGRRCPA partial exemption volume test applies to open-end lines of credit;
- Which of the required fields on the LAR are applicable to open-end lines of credit; and
- Which of the required fields have altered content for an open-end line of credit.
The program is designed for loan officers, compliance officers, loan processors and clerks and auditors.
Jack Holzknecht is the CEO of Compliance Resource, LLC. He has been delivering the word on lending compliance for 45 years. In 40 years as a trainer over 150,000 bankers (and many examiners) have participated in Jack’s live seminars and webinars. Jack’s career began in 1976 as a federal bank examiner. He later headed the product and education divisions of a regional consulting company. There he developed loan and deposit form systems and software. He also developed and presented training programs to bankers in 43 states. Jack has been an instructor at compliance schools presented by a number of state bankers associations. As a contractor he developed and delivered compliance training for the FDIC for ten years. He is a Certified Regulatory Compliance Manager and a member of the National Speakers Association.
October 5, 2021