On September 23, 2022, the United States District Court for the District of Columbia entered a judgment invalidating the CFPB’s rule raising the HMDA reporting threshold to 100 covered loans. The court's decision returns the operative HMDA reporting threshold to 25 closed-end loans originated. Notably, the court’s ruling did not alter the reporting threshold for open-end lines of credit, which remains at 200 covered lines of credit. The court’s decision makes it clear lenders that originated 25 or more closed-end loans and/or 200 or more open-end lines of credit during either 2021 and 2022 will now have a reporting obligation in 2023. While the CFPB could appeal this decision, smaller institutions that previously had been exempted will now need to comply.

RISKEXEC IS HERE TO HELP

The RiskExec team can help you meet this sudden change in the regulatory landscape with its competitively priced “Small HMDA-Filer Package” designed to help your institution rapidly respond and comply. This tailored offering combines our best-in-class HMDA software module with our unparalleled expertise and support:

• Data Scrub:  Edit checks for data that match regulatory requirements, plus additional out-of-the-box data screens to further identify risk areas and potential for data corrections.
• Affix/Correct Geographic Information: Industry leading geocoding and mapping, enabling  the accurate placement of loan applications in MSA and census tract, as well as peer comparisons. 
• Review and Submit: Easy submission file preparation and assistance. 
• Additional Support As Needed:  HMDA Scrubs, Fair Lending Risk Reviews, and/or other compliance-related advice.

Over a hundred institutions of all sizes have placed their confidence in RiskExec. You can learn more by contacting Chris Gray via email at cgray@asurity.com or via telephone at (617) 735-0475.