By: Rhonda Coggins, CRCM, National Compliance Services Director
When the Consumer Financial Protection Bureau (the Bureau) issued a new final rule amending Regulation C in 2015, it was apparent that big changes were ahead of us. That rule had four effective dates for different provisions. While stakeholders have worked diligently towards compliance over recent years, we still have one effective date ahead of us, and it’s coming up fast!
On January 1, 2020, the new quarterly reporting requirement and changes to the enforcement provisions for larger-volume reporters become effective. Additionally, there are institutional and transactional coverage changes for open-end lines of credit that become effective that date.
Who is a larger-volume reporter? A larger-volume reporter that is subject to quarterly reporting provisions is described as a financial institution that reported at least 60,000 covered loans and applications, combined, excluding purchased covered loans, in the preceding calendar year. Beginning in 2020, such reporters must submit their loan/application register (LAR) within 60 calendar days after the end of each calendar quarter, except the fourth quarter. Rather, fourth quarter information, along with the first three quarters’ information, will be contained in the institution’s annual submission.
What is the open-end lines of credit coverage change effective in 2020? At that time, the HMDA rule reduces the loan volume threshold for covered open-end lines of credit to 100 covered open-end lines of credit in each of the two preceding calendar years. As the Bureau has clarified, in 2020 an institution is subject to Reg. C if it originated at least 25 covered closed-end mortgages loans in each of the preceding two calendar years or at least 100 covered open-end lines of credit in each of the two preceding calendar years and meets other applicable coverage criteria.
In moving towards this new deadline, institutions are encouraged to review these 2020 requirements and ensure plans are being implemented to support compliance. Interested persons may find a wide variety of resources at the Bureau’s HMDA webpage here.