What is the Timeline for the CFPB's Home Mortgage Disclosure Act Final Rule?

Answer: In July of 2014 the Consumer Financial Protection Bureau (CFPB) proposed amendments to Regulation C to require collection, recording and reporting of additional information under the Home Mortgage Disclosure Act (HMDA). The CFPB issued the HMDA Final Rule in October of 2015 which changes institutional coverage in two phases. 

First, the HMDA Rule narrows the scope of depository institutions subject to Regulation C beginning on Jan. 1, 2017. A financial institution will not be subject to Regulation C in 2017 unless it meets the asset-size, location, federally related and loan activity tests under current Regulation C and it originates at least 25 home purchase loans, including refinancings of home purchase loans in both 2015 and 2016. 

Second, effective Jan. 1, 2018, the Final Rule adopts a uniform loan-volume threshold for all institutions. Beginning in 2018, a financial institution will be subject to Regulation C if it originated at least 25 covered closed-end mortgage loans or at least 100 covered open-end lines of credit in each of the two preceding calendar years, and it meets current Regulation C's asset-size, location, federally related and loan activity tests. 

For HMDA data collection through 2016, financial institutions should continue collecting 2016 data under the current rule to report in 2017. Through 2017 financial institutions should collect 2017 data under the current rule to report in 2018. For HMDA data collected on or after Jan. 1, 2018, covered institutions will follow the Final Rule. The Final Rule will require covered financial institutions to collect, record, and report additional information about originations of, purchases of and applications for covered loans. 

For additional guidance see the CFPB's HMDA Implementation Guidance here

Note: The above information is not intended to provide legal advice; rather, it is intended to provide general information about banking issues. Consult your institution's attorney for special legal advice or assistance.