HMDA Compliance

The Home Mortgage Disclosure Act (HMDA) requires credit unions to disclose certain information regarding loans originated or purchased by the credit union. HMDA is implemented by the CFPB's Regulation C which was recently amended to include home equity lines of credit, establish transactional thresholds for coverage, and expand the number of HMDA data points collected from credit unions. Most of the new HMDA requirements became effective January 1, 2018.

HMDA Data Collection Graph - May 2016
Source: May 2016 Economic & CU Monitor

Expansion of the HMDA data set to roughly 38 data points will likely necessitate major changes in the data collection processes, policies and procedures for many credit unions. More than 20% of NAFCU survey respondents manually collect data for most HMDA data points (May 2016 NAFCU Economic & CU Monitor data). Credit unions that are subject to the final regulation will need to have plans and processes in place well before the effective date.

Although confident in their credit union or third-party vendor being able to successfully implement all the changes necessitated by the new requirements by the effective date, only 10 percent of respondents have already received final updates from their vendors to implement the new data points, indicating that implementation work is still continuing despite the deferred effective date (November 2017 Economic & CU Monitor data).

Credit unions estimate an average of about 19 hours of training will be necessary to bring staff up to speed on the new HMDA data points, with initial training costs expected to average around $39,000 per credit union (November 2017 Economic & CU Monitor data).

Below you'll find credit union resources for HMDA/Regulation C compliance, including final rule summary, scope and applicability chart, insightful blog posts, articles and webcasts, to help you get up-to-speed.

Resources marked by * are member-only. If you are not a NAFCU member, learn more about membership.

Regulator Compliance Resources

Charts & Guides



NAFCU Compliance Blog Posts

Find more HMDA blog posts on The NAFCU Compliance Blog.