{"id":2680,"date":"2021-11-18T21:08:30","date_gmt":"2021-11-18T21:08:30","guid":{"rendered":"https:\/\/albanknews.com\/?p=2680"},"modified":"2021-11-18T21:08:30","modified_gmt":"2021-11-18T21:08:30","slug":"compliance-qa-partial-exemption-considerations","status":"publish","type":"post","link":"https:\/\/albanknews.com\/?p=2680","title":{"rendered":"Compliance Q&A: Partial Exemption Considerations"},"content":{"rendered":"

Question: <\/strong>What is the current open-end threshold for partial exemptions?\u00a0 When does it change?<\/p>\n

Answer<\/strong>: The partial exemption open-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 500 transactions in either of the two previous years but will be decreasing to 200 transactions on January 1, 2022.<\/p>\n

(3) …an insured depository institution or insured credit union that, in each of the two preceding calendar years, originated fewer than 500 open-end lines of credit…is not required to collect, record, or report optional data as defined in paragraph (d)(1)(iii) of this section for applications for open-end lines of credit that it receives, open-end lines of credit that it originates, and open-end lines of credit that it purchases.<\/p>\n

12 CFR 1003.3(d)(3) \u2013 https:\/\/www.consumerfinance.gov\/rules-policy\/regulations\/1003\/3\/#d-3<\/a><\/p>\n

The final rule sets the permanent open-end threshold at 200 open-end lines of credit effective January 1, 2022, upon expiration of the temporary threshold of 500 open-end lines of credit.<\/p>\n

Home Mortgage Disclosure Rule, p. 3 https:\/\/files.consumerfinance.gov\/f\/documents\/cfpb_final-rule_home-mortgage-disclosure_regulation-c_2020-04.pdf<\/a><\/p>\n

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Compliance Alliance offers a comprehensive suite of compliance management solutions. <\/strong>To learn how to put them to work for your bank, call (888) 353-3933 or email info@compliancealliance.com<\/a> and ask for our Membership Team. Not a member?<\/strong> Learn more about membership with Compliance Alliance by attending one of our live demos:<\/p>\n