Pub. 5 2017 Issue 4

www.uba.org 20 H ighlights for 2018 include: (1) Home Mortgage Disclo- sure Act (HMDA) changes; (2) amendments to the Equal Credit Opportunity Act (ECOA); (3) an increased Truth- in-Lending (TIL) threshold; (4) Community Reinvestment Act (CRA) amendments; and (5) “sunset” provisions. The time has come for the long-awaited changes affecting HMDA to hit the banking world with a bang. HMDA – version 2018 – includes changes relating to institutional and transactional coverage and data collection, recording, reporting, and disclosure. As for institutional coverage, HMDA 2018 adopts a uniform loan-volume threshold for all institutions. This means that start- ing January 1, 2018, an institution will be subject to HMDA if it originated 25 or more covered closed-end mortgage loans in each of the preceding calendar years, or if it originated 100 or more covered open-end lines of credit in each of the past two years. Of course, the institutions making these loans also need to meet other applicable coverage requirements to be subject to HMDA. As for the amendments to transactional coverage, HMDA 2018 modifies the types of transactions that are covered. Basically, the new version of HMDA adopts a dwelling-secured standard. As of January 1, 2018, covered loans will include both closed-end mortgage loans and open-end lines of credit secured by a dwell- ing. Another major change to this portion of HMDA concerns business-purpose loans. Starting January 1, 2018, dwelling-se- cured, business-purpose loans and lines of credit will constitute covered loans if they are home purchase loans, home improve- ment loans, or refinancings. HMDA AND COMPANY— HIGHLIGHTS FOR THE UPCOMING YEAR This past year has shaped up to be quite a ride but buckle up—2018 is fast approaching. By Sarah Sauceda, Associate General Counsel COMPLIANCE CORNER