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December 31, 2013

HMDA asset-size threshold $43 million in 2014

Jan. 2, 2014 – The CFPB announced an increase in the asset-size threshold for credit unions and other institutions to be exempt from Regulation C, under the Home Mortgage Disclosure Act – making the exemption threshold $43 million for 2014.

The threshold was established with the understanding that it would be automatically adjusted every year based on the annual percentage increase in the average Consumer Price Index for urban wage earners and clerical workers. The increase went into effect yesterday, meaning that all credit unions, savings associations and banks with assets of $43 million or less as of December 31, 2013 will be exempt from collecting HMDA data in 2014. However, the CFPB reminded institutions that they are still required to report any data the law required them to collect in 2013.

The HMDA and Regulation C requires data collection and reporting about mortgage loan applications, originations, purchases and refinancing. The data also includes information on the race, ethnicity, gender, and income level of loan applicants, as well as the location of the property being purchased. This information allows the CFPB to determine potential discrimination in lending patterns.