HMDA and Open-End Lines of Credit – ON-DEMAND WEBINARS

Recorded: December 1, 2021

Presented by: Ms. Anetria Cohen, VP and Senior Consultant

A two-hour webinar that will cover HMDA requirements as they relate to open-end lines of credit.

OVERVIEW

Prior to 2018, creditors had the option, but were not required, to report open-end credit transactions for Home Mortgage Disclosure Act (HMDA, as implemented in Regulation C) purposes. Although those rules changed, the new regulations still exempt many institutions from having to report them due to a threshold exception – that is, if an institution originated fewer tthan 500 open-end lines of credit in each of the two previous calendar years, it is not required to report such loans. The threshold changed yet again – to 200, effective January 1, 2022 – a few months ago, with the effect that many more institutions may be required to report open-end transactions in the future.

Although reporting open-end lines of credit seems relatively straightforward, there are some areas that can be confusing or tricky. For example, what is an “open-end line of credit”? Which transactions does an institution have to include to determine whether it meets the threshold? Also, open-end transactions are structured in ways that are different than closed-end. Are there any specific rules or considerations for open-end transactions ? How does reporting data for open-end transactions differ?

This webinar will discuss the HMDA requirements as they relate to open-end credit transactions. We will discuss the threshold exemptions, the importance of “application,” and how having an open-end transaction will impact data reporting.

HERE IS WHAT YOU’LL LEARN:

In this webinar, you will learn the following:

• Definition of “open-end line of credit”
• Coverage, including the open-end threshold exemption (now and in the future)
• Importance of the definition of “application”
• Data points that may be a concern, including:
  • Amount of the loan
  • Preapprovals
  • APR/APOR Rate spread calculation
  • HOEPA
  • Loan term
  • Introductory rate
• Data points that are not applicable