Compliance Alliance: Open-end Threshold for Partial Exemptions

Question: What is the current open-end threshold for partial exemptions?  When does it change?

Answer: 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.

(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.

12 CFR 1003.3(d)(3) –

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.

Home Mortgage Disclosure Rule, p. 3


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