Buchalter Client Alert COVID-19: New HMDA Final Rule Raises Loan Origination Reporting Threshold; Particular Significance for Certain Multifamily Lenders

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On April 16, the CFPB issued a HMDA final rule increasing the number of closed-end mortgage loans and/or open-end mortgage loans an institution must originate before it meets HMDA’s coverage thresholds. Effective July 1, 2020, institutions originating fewer than 100 closed-end mortgage loans in either of the two preceding calendar years will not have to report such data effective July 1, 2020. Additionally, the permanent open-end mortgage loan reporting threshold will become 200 open-end mortgage loans effective January 1, 2022, upon the expiration of the current temporary threshold of 500 open-end lines of credit.

This change will allow multifamily lenders who do not originate single-family loans and who originate fewer than 100 multifamily loans annually to avoid HMDA obligations.  It will also benefit institutions which make small numbers of closed-end or open-end mortgage loans.

The new rule may be found HERE.

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