CFPB Provides Guidance on HMDA Loan Reporting Threshold

The Consumer Financial Protection Bureau said it does not intend to “initiate enforcement actions or cite Home Mortgage Disclosure Act violations for failures to report closed-end mortgage data collected in 2022, 2021 and 2020” for covered institutions that originated at least 25 closed-end loans, but less than 100 closed-end loans in each of the previous two calendar years.

The CFPB update comes after the U.S. District Court for the District of Columbia ruled in late September the HMDA reporting threshold is now 25 closed-end loans in each of the preceding two years rather than the 100 closed-end loan threshold set by the 2020 HMDA Final Rule.

Click here for a detailed Mortgage Bankers Association summary of that court ruling.

The Bureau in its blog post said that it would not view action regarding affected financial institutions’ HMDA data as a priority, recognizing that they “may need time to implement or adjust policies, procedures, systems, and operations to come into compliance with their reporting obligations.”

MBA will continue to engage with the CFPB on the impact of the ruling and steps to help the industry comply. For more information, contact MBA’s Stephanie Milner at (202) 557-2747.