The Federal Financial Institutions Examination Council (“FFIEC”) recently issued the 2020 edition of A Guide to HMDA Reporting: Getting It Right! for Home Mortgage Disclosure Act (“HMDA”) data collected in 2020 and reported by March 1, 2021. The guide contains a summary of key requirements to assist financial institutions in meeting data collection, reporting and disclosure requirements.
The 2020 version of the guide is updated to incorporate changes implemented by the HMDA final rule issued by the CFPB on October 19, 2019 amending Regulation C. This includes the extension of the temporary adjustment to the institutional and transactional coverage threshold for open-end transactions. The temporary origination threshold remains at 500 open-end lines of credit in each of the preceding calendar years for 2020 and 2021. The CFPB is expected to provide a permanent threshold rule sometime during 2020. Additionally, the guide incorporates partial exemptions added by the Economic Growth, Regulatory Relief and Consumer Protection Act, and addresses the use of a non-universal loan identifier for partially exempt transactions.
DocMagic’s recent article regarding the final rule amending HMDA (Regulation C) can be found here.
