ARLINGTON, Va.—A compliance deadline relating to home equity lines of credit is coming up “sooner than you’d like,” according to NAFCU Director of Regulatory Compliance Brandy Bruyere.
Most of the new Home Mortgage Disclosure Act final rule requirements become effective Jan. 1, 2018, pointed out Bruyere, and establish transactional thresholds for coverage and expand the number of HMDA data points collected from credit unions.
“Several credit unions have asked what this means for HELOCs, since the effective date of the new definition of covered loan, which brings HELOCs into the scope of the rule, is not until January 1, 2018,” said Bruyere. “We have blogged about this a couple of times, but the key effective date for collecting on the new HMDA data points is based on the credit union taking ‘final action’ on the loan/application on or after Jan. 1, 2018.
“In other words, will HELOC applications accepted in late 2017 but with a final action taken in 2018 be subject to the new HMDA reporting requirements? The short answer is yes,” Bruyere continued.
She noted that HMDA compliance is triggered by the final action on an application, not by the application date.