The recent release of the 2019 HMDA Final Rule, published on October 10th, extends the temporary guidance that was published in the 2018 rule, making it effective until January 1, 2022. There were no newly published changes noted in the final rule, making it an affirmation of previous guidance. From our perspective, this is good news. It means that there were no changes in the way we currently support HMDA on our loan origination platform. No updates required – the Mortgage Cadence platform is fully equipped to handle the final rule.
That said, the rule did provide some
additional information related to definitions and/or guidance for partially exempt transactions,
- Insured credit union
- Insured depository institution
- Optional data
- Partially exempt
- Merger and acquisition guidance
- Defined when the partial exemption can be
utilized by affiliates
- Clarified and outlined what “preceding calendar
year” refers to in the rule
- Information regarding ULI or NULI applicability
- Additional privacy guidance
As noted in the CFPB announcement, the
- Extends the temporary threshold of 500 open-end
lines of credit for open-end institutional and transactional coverage until
January 01, 2022 (baring no additional changes).
- For data collection years 2020 and 2021,
covered financial institutions that originated fewer than 500 open-end lines of
credit in either of the two preceding calendar years will not need to collect,
record, or report data with respect to open-end lines of credit.
- The data collection threshold will change on
January 01, 2022, requiring any institution to file if they have at least 200
open-end lines of credit in either of the two preceding calendar years.
- There was no change in the data points
collected for institutions that must report all data fields, or those that
qualify for the partial exemption.
- The CFPB extended a commentary period for the
ANPR regarding HMDA data points that was originally opened in May 2019 and was
to originally close on July 8th, but was extended until Oct. 15th. So, there is
more to come on this, which may have an impact on the 2019 HMDA Rule.
We will continue to monitor the issue, and
should material changes result in changes to our technology, we’ll be in
discussions with our clients as soon as they are published.