HMDA Small Entity Guide Released
On Jan. 24, 2020, the CFPB published an updated Home Mortgage Disclosure Act (HMDA) Small Entity Compliance Guide
incorporating content from the HMDA Final Rule issued on Oct. 10, 2019. The purpose of the guide is to provide an easy-to-
use summary of Regulation C to highlight information financial institutions might find helpful when implementing the HMDA
Rule. Below is a summary of the newly released compliance guide.
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Institutional Coverage (Section 2.1) Transactional Coverage (Section 2.2)
This section of the guide discusses the temporary higher
loan-volume threshold for open-end lines of credit that
went into effect Jan. 1, 2018, set to be lowered Jan. 1,
2022. The HMDA Rule modifies the types of transactions
subject to Regulation C and generally adopts a dwelling-
secured standard for transactional coverage. This rule’s
effective dates are as follows:
Absent further rulemaking, starting in 2022, HMDA
reduces the loan-volume threshold for covered open-end
lines of credit from 500 to 100 covered open-end lines of
credit in each of the two preceding calendar years. The
other institutional coverage criteria do not change in 2022.
Thus, a depository financial institution or non-depository
financial institution is subject to Regulation C if it
originated at least 25 covered closed-end mortgage loans
in each of the preceding two calendar years, or at least
500 covered open-end lines of credit in each of the two
preceding calendar years and meets the other applicable
coverage criteria. • Jan.1, 2018 for data collected on or after Jan. 1, 2018
(to be reported in or after 2019)
• Jan. 1, 2022 and applicable for data collected on or
after Jan. 1, 2022 (to be reported in or after 2023) for
a change to the exclusion for open-end lines of credit.
Section 4 of the guide provides an expanded discussion
of transactional coverage.
Required Data Points (Section 2.3)
Section 3 of the guide provides an expanded discussion Here information related to the May 24, 2018 rule change
is covered. This rule change created partial exemptions
permitting certain financial institutions to exclude 26 data
points when collecting, recording and reporting HMDA
of institutional coverage. data for certain transactions.