The Fair Lending and HMDA Conundrum
Earlier this year, many smaller institutions were elated at the prospect that they
would no longer be subject to the HMDA data collection and report rules as of July 1,
On April 16, 2020, the Consumer Financial Protection Bureau (Bureau) issued a final
rule amending Regulation C. This final rule adjusted Regulation C’s institutional and
transactional coverage thresholds for closed-end mortgage loans and open-end lines
• Effective July 1, 2020, the final rule permanently raises the closed-end coverage
threshold from 25 to 100 closed-end mortgage loans in each of the two
preceding calendar years.
• Effective January 1, 2022, when the temporary threshold of 500 open-end lines
of credit expires, the final rule sets the permanent open-end threshold at 200
open-end lines of credit in each of the two preceding calendar years.