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NCUA Regulatory Alert notes changes in HMDA reporting threshold
The NCUA last week released a Regulatory Alert notifying credit unions that the Home Mortgage Disclosure Act (HMDA) threshold for reporting data on closed-end mortgage loans is now 25 loans in each of the two preceding calendar years. This comes after the U.S. District Court for the District of Columbia vacated a portion of the CFPB’s 2020 HMDA Final Rule, which had raised the reporting threshold to 100 loans.
The agency said it will not issue enforcement actions or cite HMDA violations for not reporting closed-end mortgage loan data collected in the last three years for credit unions that originated at least 25 closed-end mortgage loans in each of the two preceding calendar years but fewer than 100 closed-end mortgage loans in either or both of the two preceding calendar years. Additionally, the NCUA noted that it will take a flexible supervisory approach to give more time for credit unions to comply with the reporting requirements.
NAFCU collaborated on a joint trades letter to the Federal Financial Institutions Examination Council (FFIEC), which requested more flexibility to comply with the changes in the HMDA reporting threshold.
The association will continue working with federal financial regulators to limit the regulatory burden on credit unions.