Regulatory Aware

If your borrowing union renders home-based mortgage loans and match the four requirements outlined less than, you need to follow the consumer Financial Protection Bureau’s (CFPB) Control C, and this executes the home Financial Disclosure Act (HMDA). 1

HMDA Data Range Standards to own Calendar year 2024

1. The borrowing union’s overall property as of , exceeded $56 million; 2
2. Your own borrowing from the bank union had a house or department workplace in the a beneficial Metropolitan Statistical Town on the ;
3. The borrowing partnership began one home purchase financing (other than short term financial support instance a casing loan) or refinanced a house buy loan, covered because of the an initial lien toward a one-to-four-device dwelling throughout 2023; and you may
4. Your credit union originated at least 25 covered closed-end mortgage loans in per of the 2 preceding calendar years (2022 and 2023) or at least 200 covered open-end lines of credit in each of the 2 preceding calendar years (2022 and 2023).

If for example the borrowing from the bank commitment match all requirements, you need to gather HMDA data throughout season 2024 and complete the knowledge into CFPB zero later on than . step three Should your borrowing from the bank union will not satisfy all four criteria, you are excused out of submitting HMDA studies for home loan programs canned within the season 2024.

HMDA Studies Limited Exemptions

Regulation C provides that a credit union is not required to collect or report certain data points with respect to closed-end mortgage loans if the credit union originated fewer than 500 covered closed-end mortgage loans in each of the 2 preceding calendar years. Similarly, a credit union is not required to collect or report certain data points with respect to open-end lines of credit if the credit in desperate need of money fast union originated fewer than 500 covered open-end lines of credit in each of the 2 preceding calendar years.

While the desk means, the fresh partial exemption to have signed-stop mortgages and also the limited exception to this rule to possess open-prevent lines of credit operate separately of a single a special. For this reason, a credit relationship could possibly get trust one to partial exemption yet not one other.

There are 48 data issues necessary for Controls C. The fresh control determine you to definitely twenty six ones studies circumstances aren’t required to feel gathered and reported in the event that a transaction qualifies getting a partial different. The control also determine you to 22 of these study products need certainly to be amassed and you can advertised no matter if a purchase qualifies to have good limited exemption. Appendix F (Partial Exemptions Maps) in the 2023 The basics of HMDA Revealing: Getting hired Best! contours this new 26 data circumstances protected by this new limited exemptions and the fresh new twenty-two data items maybe not covered by the brand new limited exemptions.

Due to the fact portrayed regarding dining table significantly more than, within the 2024, Borrowing from the bank Partnership A perform simply be necessary to collect and statement the twenty two non-excused data things, but not the newest twenty six excused studies things, for its closed-prevent mortgages and software. Borrowing from the bank Relationship A perform, although not, be required to gather and declaration most of the forty-eight analysis things for the discover-end personal lines of credit money and you can apps.

Inside 2024, Borrowing Commitment B create only be expected to collect and report the newest 22 low-excused study things, however new 26 exempt research affairs, because of its unlock-avoid credit lines loans and you will software. Borrowing Commitment B carry out, although not, be required to collect and you may declaration all of the 48 research issues for its closed-end mortgage loans and you may applications.

When you look at the 2024, Borrowing from the bank Relationship C could well be necessary to gather and you can declaration every 48 investigation situations for the signed-avoid mortgages and you may applications and its unlock-avoid credit lines financing and applications.

Please note that a credit union may willingly report any or all of the 26 exempt data points. However, if a credit union opts to report an exempt data point voluntarily, it must report all data fields that are part of that data point.

Distribution off 2023 HMDA Data

Given that a note, borrowing from the bank unions at the mercy of HMDA study range criteria within the twelve months 2023 need certainly to fill out their financing/software register investigation into CFPB by using the HMDA Platform because of the . To determine whether your borrowing relationship need to fill out HMDA study having season 2023 craft, delight remark this new 2023 HMDA Organization Exposure Graph.

The NCUA wants all of the borrowing partnership expected to statement 2023 HMDA study to submit their document toward CFPB from the , deadline. Borrowing from the bank unions appearing with the an unpaid filers number becomes subject in order to civil currency penalty tests.