QUESTION: What is the current closed-end threshold for partial exemptions? When does it change?
ANSWER: The partial exemption closed-end threshold is currently 500 transactions in each of the two previous years and is not currently scheduled to change. There is currently a full reporting exemption which is currently set at 100 transactions in either of the two previous years, which increased from 25 transactions on January 1, 2020.
(2) …an insured depository institution or insured credit union that, in each of the two preceding calendar years, originated fewer than 500 closed-end mortgage loans…is not required to collect, record, or report optional data as defined in paragraph (d)(1)(iii) of this section for applications for closed-end mortgage loans that it receives, closed-end mortgage loans that it originates, and closed-end mortgage loans that it purchases.
12 CFR 1003.3(d)(2) – https://www.consumerfinance.gov/rules-policy/regulations/1003/3/#d-2
Effective July 1, 2020, this final rule permanently raises the closed-end coverage threshold from 25 to 100 closed-end mortgage loans in each of the two preceding calendar years.
Home Mortgage Disclosure Rule, p. 2 https://files.consumerfinance.gov/f/documents/cfpb_final-rule_home-mortgage-disclosure_regulation-c_2020-04.pdf
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