All in HMDA

On April 13, 2023, the OCC announced that the Federal Financial Institutions Examination Council (FFIEC) had issued the 2023 edition of A Guide to HMDA Reporting: Getting It Right! for Home Mortgage Disclosure Act (HMDA)-related data collected in 2023 and reported in 2024. This longstanding compliance resource has regularly been used by financial institutions as a “go-to” HMDA resource as it can help financial institutions better understand HMDA requirements, including the data collection and reporting provisions.

On March 15, 2023, the CFPB published the 2023 HMDA Institutional Coverage Chart  and 2023 HMDA Transactional Coverage Chart. The updated charts are effective January 1, 2023. The updated coverage charts reflect the reduced 25 closed-end loans in each of the previous two calendar years threshold for reporting closed-end applications and loans.

On February 3, 2023, the FDIC issued a Financial Institution Letter to inform supervised institutions of recent changes regarding the Home Mortgage Disclosure Act (HMDA) reporting threshold for closed-end mortgage loans and the FDIC’s supervisory approach for enforcing related requirements. According to the FDIC, it does not intend to initiate enforcement actions or cite HMDA violations for certain failures to report closed-end mortgage data collected in the last three years.

On February 2, 2023, the NCUA issued a letter addressed to federally insured credit unions regarding the change to HMDA’s closed-end loan reporting threshold. According to the NCUA, the agency recognizes that credit unions affected by this change may need time to implement or adjust policies, procedures, systems, and operations to achieve compliance with these reporting requirements. Thus, the NCUA intends to take a flexible supervisory and enforcement approach similar to the approach being taken by the CFPB.

On February 1, 2023, the OCC issued a bulletin to inform banks and OCC examining personnel that the loan origination threshold for reporting Home Mortgage Disclosure Act (HMDA) data on closed-end mortgage loans has changed. This is after a court decision was issued that the threshold for reporting is now 25 closed-end mortgage loans originated in each of the two preceding calendar years.