HMDA again?

Q.  Heather, I’ve heard some noise about HMDA (the Home Mortgage Disclosure Act, Regulation C). What are the changes? How can I tell if my credit union has to report HMDA data?

A.  Great Questions! Oh boy! Yes, there has been some movement with HMDA in the past few weeks. The Consumer Financial Protection Bureau (CFPB) published a blog post on December 6 regarding changes to HMDA’s closed-end loan reporting threshold.

To explain what’s going on, it’s helpful to cover the criteria that triggers HMDA reporting for depository financial instutions like credit unions. Bonus – you asked about that anyhow, so let’s kill two birds with one stone.  A credit union that meets all of the following criteria will need to report HMDA data:

  • Meeting a cetain asset size (currently $50 million, increases every year or so)
  • Having a home or branch office located in an Metropolitan Statistical Area.
  • Originated at least one home purchase or refinancing of a home purchase loan secured by a first lien on a 1-4 family dwelling during the last calendar year.
  • Institution is federally insured or regulated (all Utah credit unions meet this criteria).
  • Originated at least 25 closed-end mortgage loans in each of the two preceding calendar years OR 200 HELOCs in each of the two preceding calendar years.

That last criteria is where the change comes in. In 2020, the CFPB issued a new rule that increased the HMDA closed-end reporting threshold from 25 to 100 closed-end loans. Yay, we love regulatory reflief! However, a recent court ruling vacated that rule. (Boo!) All of a sudden several credit unions that had been able to stop reporting, must be prepared to start again.  We also have a few credit unions that will be brand new reporters.

Because of this change, we are planning on holding a HMDA 101 class on Wednesday January 11, 2023, to discuss all things HMDA. If you are a new HMDA reporter – never fear! Although Reg C is quite technical, it’s not impossible, and I’ll be here to help you navigate it.