HMDA and Open-End Lines of Credit

Recorded: December 5, 2024

Presented by: Mark Burnside, Director, Forvis Mazars, LLP.

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

Reporting open-end transactions for Home Mortgage Disclosure Act (HMDA, as implemented in Regulation C) purposes has not been required for many institutions. Prior to 2018, institutions had the option but were not required to. As of 2018, the rules were revised to generally require reporting for open-end transactions, but many smaller institutions are exempted due to a threshold exception. Effective January 1, 2022, this threshold was reduced to 200, causing many more institutions be subject to HMDA requirements for open-end lines of credit.

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 – that is, when does having an open-end line of credit cause specific concerns? 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