In the 2015 Home Mortgage Disclosure Act (“HMDA”) Rule, the Bureau established an institution and transaction threshold which dictates whether institutions must report certain information under HMDA. The 2015 Rule set the reporting threshold for open-end lines of credit at 100 loans in the preceding two calendar years. Prior to its effective date, the reporting threshold was temporarily increased from 100 to 500 loans. This threshold was effective for 2018 and 2019. The CFPB has extended the term of temporary reporting threshold; for data collected through January 1, 2022, the HMDA reporting threshold for open-end lines of credit will continue to be 500 loans.
