ARLINGTON, Va.—NAFCU has summarized the CFPB's changes to its Home Mortgage Disclosure Act rule, including various technical adjustments and reporting requirements for home equity lines of credit.
NAFCU Vice President of Regulatory Compliance Brandy Bruyere addressed the changes, including various technical adjustments and reporting requirements for home equity lines of credit for credit unions in the trade associations latest Compliance Blog post.
Bruyere highlights a few of the technical amendments, including counteroffers, temporary and construction-only loans, and loan purpose for purchase loans originated before Jan. 1, 2018. She said there are many more technical amendments and that NAFCU, in the coming weeks, will publish a Final Regulation for members.
Regarding the amended open-end line of credit threshold, Bruyere says the changes finalized by the CFPB last week increase the open-end threshold reporting requirements from 100 loans to 500 loans, but that increase is only through 2018 and 2019.
Bruyere noted that some credit unions have had questions regarding reporting methods for 2017 HMDA data. She said the CFPB is developing a web-based submission tool that will be intaking and processing HMDA data. Beginning in 2018, credit unions will use the CFPB website and its submission tool/HMDA platform. That platform will be ready for testing in the fourth quarter, she said.
Beginning in 2019, reporting will be done under the new rule, "meaning the inclusion of instructions for submitting the new data collected in 2018. However, the actual method of submission – the CFPB's HMDA Platform – will have already been used in 2018 while submitting 2017 data," said Bruyere.