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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 recording is viewed
The recording 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 recording is designed for loan officers, compliance officers, loan processors and clerks and auditors.