Removing Barriers Blog

CFPB Temporarily Increases HMDA HELOC Reporting Threshold
Posted August 24,2017 by CUNA Advocacy

Today, the CFPB issued a final rule that temporarily increases the threshold for collecting and reporting HELOC data under HMDA. Under the Regulation C rules that are scheduled to take effect in January 2018, credit unions and other financial institutions would have been required to report HELOCs if they made 100 such loans in each of the last two years. The final rule increases that threshold to 500 loans through 2018 and 2019. Over the next two years, the Bureau will reconsider whether to adjust the threshold amount and/or duration of the temporary increase. 

CUNA appreciates the Bureau’s effort to provide flexibility for credit unions making a relatively low number of HELOCs, and we believe today’s final rule is a step in the right direction. However, as detailed in our comment letter to the CFPB, we believe a complete exemption from the HELOC reporting requirement would be more appropriate for credit unions. Particularly, given there has been no evidence of wrongful conduct and credit union HELOC data would ultimately be inconclusive because of their field of membership requirements. 

We will continue to work with the Bureau to achieve greater relief for credit unions in all areas, including HMDA.