Among them, 6.3 million were closed-end mortgage
originations, 1.1 million were open-end line of credit originations, and, pursuant to the EGRRCPAs partial exemptions, 283,000 were originations for which financial institutions did not indicate whether they were closed-end or open-end.
The two forms were typically given to consumers within three days after they applied for closed-end mortgage
loans, and updated versions of one (and often both) of these forms were provided just prior to, or at the time of loan closing.
ATR mandates a repayment analysis for closed-end mortgage
loans and prohibits certain loan terms and conditions.
Certain depository institutions originating fewer than 25 closed-end mortgage
loans or fewer than 100 open-end lines of credit each year may no longer be subject to HMDA's reporting requirements at all.
To simplify the analysis, we focus on consumers who had exactly one closed-end mortgage
with an outstanding balance of at least $50,000 as of the end of 2009 and stayed in the same census block over the course of 2010 (a proxy for not having changed residence; we simply want to omit from the analysis those who moved).
It manages Second Angel Commercial Mortgage Fund l LLC, a $50 million closed-end mortgage
fund that lends money to builders, developers, business and homeowners for short periods of time.
In May, the Consumer Bureau issued a proposal to raise the HMDA threshold for reporting closed-end mortgage
loans, as well as a proposal that would prevent the public from learning about predatory and discriminatory lending activity in local communities, particularly rural communities.
In addition, under a new standardized reporting threshold, institutions that made less than 25 closed-end mortgage
loans in each of the two preceding calendar years or fewer than 100 covered open-end lines of credit in each of the two preceding calendar years will be exempted from the rule.
For closed-end mortgage
loans if the institution originated fewer than 500 closed-end mortgage
loans in each of the two preceding calendar years.
TRID applies to nearly all closed-end mortgage
loans regardless of a credit union's asset size or pricing of the mortgage.
1310, provides an exemption from new HMDA data reporting requirements for small financial institutions that originate 500 closed-end mortgage
loans or 500 open-end lines of credit.
Other anecdotal evidence includes the fact that HFC and American General withdrew from the closed-end mortgage
market because of insufficient profits.