The CFPB proposed changes to HMDA in April and July which became final August 24. Most importantly, they have temporarily increased the threshold for collecting and reporting data with respect to open-end lines of credit from 100 to 500 for calendar years 2018 and 2019. Other changes include a reporting exception for certain transactions related to New York CEMAs, clarification of transactions excluded as temporary financing, the definition of multifamily dwelling, reporting requirements for home improvement loans secured by mixed-use property, the meaning of Automated Underwriting System, and the meaning of income. Finally, further clarification is provided regarding the collection of Race and Ethnicity Information. We invite you to reach out to us for further detail on any of these matters.
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