The 2020 HMDA reporting threshold of 100 closed-end mortgage originated loans has been reversed back down to the 2017 reporting threshold of 25 loans. On September 23, 2022, the United States District Court of the District of Columbia issued an order vacating the 2020 HMDA (Home Mortgage Disclosure Act) final rule that eliminated the HMDA reporting requirements for a significant number of financial institutions.
Thus, financial institutions that originated more than 25 closed-end mortgage loans in each of the prior two years (2021 & 2022) will be required to report HMDA data for the 2023 HMDA reporting cycle which is required to be submitted March 1, 2024. This would include loans originated from January 1, 2023, to December 31, 2023. The reporting requirements still require the financial institution to have at least 1 branch located within a Metropolitan Statistical Area and the Bank must exceed the asset threshold for HMDA reporting. The asset threshold was $50 million dollars for 2022.
According to the CFPB Press Release, the CFPB does not intend to initiate enforcement actions or cite HMDA violations for reporters who failed to report HMDA data in 2020, 2021, or 2022. The open-end reporting threshold remains at 200 originated open-end mortgage secured transactions. For more information, please see the CFPB press release below.
CFBP Revises Closed End Threshold
The Georgia Bankers Association will be hosting Steve H. Powell & Company President W. Brad Washburn in Macon, Georgia on Wednesday December 14, 2022, for a HMDA Workshop. The HMDA Workshop will cover all things HMDA. For more information see the link below from the GBA.
GBA HMDA Workshop