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, including:
- 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 final rule:
- 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.