Skip to main content

NCUA Issues HMDA Regulatory Alert for 2024

 


Home Mortgage Disclosure Act Data Requirements

Subject
HMDA
To
Federally Insured Credit Unions
Status
Active

Dear Boards of Directors and CEOs:

If your credit union makes residential mortgage loans and meets all four criteria outlined below, you must comply with the Consumer Financial Protection Bureau’s (CFPB) Regulation C, which implements the Home Mortgage Disclosure Act (HMDA).1

HMDA Data Collection Requirements for Calendar Year 2024

Regulation C requires you to collect HMDA data associated with mortgage loan applications processed during 2024 if:

  1. Your credit union’s total assets as of December 31, 2023, exceeded $56 million;2
  2. Your credit union had a home or branch office in a Metropolitan Statistical Area on December 31, 2023;
  3. Your credit union originated at least one home purchase loan (other than temporary financing such as a construction loan) or refinanced a home purchase loan, secured by a first lien on a one-to-four-unit dwelling during 2023; and
  4. Your credit union originated at least 25 covered closed-end mortgage loans in each 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 your credit union meets all four criteria, you must collect HMDA data during calendar year 2024 and submit the data to the CFPB no later than March 3, 2025.3 If your credit union does not meet all four criteria, you are exempt from filing HMDA data for mortgage loan applications processed in calendar year 2024.

HMDA Data Partial Exemptions

Regulation C contains partial exemptions from HMDA’s requirements for certain transactions.

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 union originated fewer than 500 covered open-end lines of credit in each of the 2 preceding calendar years.

Section 1003.3(c) of Regulation C lists excluded (not covered) transactions.

The table below provides partial exemption examples.

Credit Union Loan Type Originations During Calendar Year 2022 Originations During Calendar Year 2023 Partial Exemption In 2024
A Closed-end mortgage loans

Open-end lines of credit		 425

500		 450

525		 Only closed-end mortgage loans are exempt
B Closed-end mortgage loans

Open-end lines of credit		 475

400		 500

425		 Only open-end lines of credit are exempt
C Closed-end mortgage loans

Open-end lines of credit		 525

600		 550

625		 Neither exemption applies

As the table indicates, the partial exemption for closed-end mortgage loans and the partial exemption for open-end lines of credit operate independently of one another. Thus, a credit union may rely on one partial exemption but not the other.

There are 48 data points required by Regulation C. The regulation specifies that 26 of these data points are not required to be collected and reported if a transaction qualifies for a partial exemption. The regulation also specifies that 22 of these data points must be collected and reported even if a transaction qualifies for a partial exemption. Appendix F (Partial Exemptions Charts) in the 2023 A Guide to HMDA Reporting: Getting It Right! outlines the 26 data points covered by the partial exemptions and the 22 data points not covered by the partial exemptions.

As illustrated in the table above, in 2024, Credit Union A would only be required to collect and report the 22 non-exempt data points, but not the 26 exempt data points, for its closed-end mortgage loans and applications. Credit Union A would, however, be required to collect and report all 48 data points for its open-end lines of credit loans and applications.

In 2024, Credit Union B would only be required to collect and report the 22 non-exempt data points, but not the 26 exempt data points, for its open-end lines of credit loans and applications. Credit Union B would, however, be required to collect and report all 48 data points for its closed-end mortgage loans and applications.

In 2024, Credit Union C would be required to collect and report all 48 data points for both its closed-end mortgage loans and applications and its open-end lines of credit loans and applications.

Please note that a credit union may voluntarily 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.

Submission of 2023 HMDA Data

As a reminder, credit unions subject to HMDA data collection requirements in calendar year 2023 must submit their loan/application register data to the CFPB using the HMDA Platform by March 1, 2024. To determine if your credit union must submit HMDA data for calendar year 2023 activity, please review the 2023 HMDA Institutional Coverage Chart.

The NCUA expects every credit union required to report 2023 HMDA data to submit its file to the CFPB by the March 1, 2024, deadline. Credit unions appearing on a delinquent filers list could become subject to civil money penalty assessments.

Additional Information

Additional resources, including the Filing Instructions Guide for HMDA data collected in 2023, can be found on the Resources for HMDA filers page on the CFPB’s website. Technical questions about reporting HMDA data should be directed to hmdahelp@cfpb.gov.

If you have questions about the information in this Regulatory Alert, please contact the NCUA’s Office of Consumer Financial Protection at 703.518.1140 or ComplianceMail@ncua.gov. You can also contact your NCUA regional office or your state supervisory authority.

Sincerely,

/s/

Todd M. Harper
Chairman

Comments

Post a Comment

Please no profanity or political comments.

Popular posts from this blog

Update: First Responder Credit Unions Academy (FRCUA) Udates

In an ongoing effort to keep your FRCUA education current, modules are continually updated to reflect current NCUA and other regulatory agency requirements. As an example, BSA 26 now includes  Artificial Intelligence and BSA,  Elder Financial Exploitation,  Pig Butchering & BSA, and Executive Order –  Free and Fair Banking.
Post a Comment
Read Complete Article HERE>»

Mortgage Rates Tick Down

MCLEAN, Va.--Mortgage rates moved slightly lower this week, with the 30-year fixed-rate mortgage averaging 6.56%, Freddie Mac reported. “Mortgage rates are at a 10-month low,” said Sam Khater, Freddie Mac’s chief economist. “Purchase demand continues to rise on the back of lower rates and solid economic growth. Though many potential homebuyers still face affordability challenges, consistently lower rates may provide them with the impetus to enter the market.” The 30-year FRM averaged 6.56% as of Aug. 28, down from last week when it averaged 6.58%. A year ago at this time, the 30-year FRM averaged 6.35%. The 15-year FRM averaged 5.69%, unchanged from last week. A year ago at this time, the 15-year FRM averaged 5.51%, Freddie Mac said. ____________________________________________ Check out NCOFCU's additional features: First Responder Credit Union Academy Podcasts YouTube Mini's Blog Job Board
Post a Comment
Read Complete Article HERE>»

SIGN UP FOR YOUR CUSTOM HEALTH INSURANCE SOLUTION TODAY

 https://bizu65.allstatehealth.com/?password=demo ____________________________________________ Check out NCOFCU's additional features: First Responder Credit Union Academy Podcasts YouTube Mini's Blog Job Board
Post a Comment
Read Complete Article HERE>»

Wendelville Fire Chief Andrew Pilecki re-elected to FASNY board

Andrew Pilecki, the current fire chief of Wendelville Volunteer Fire Company, has been re-elected to the board of directors of the Firefighters Association of the State of New York. Pilecki has been a member of the fire service for more than four decades, including the past 22 years as a responder with the Wendelville company. Previously he was an active member of Columbia Hook and Ladder Co. He’s also a former assistant director of emergency management for the City of North Tonawanda. FASNY directors serve five-year terms of office. During his first term, Pilecki was instrumental in supporting the association’s pandemic response, championed fire company recruitment and retention efforts, and worked to amplify the needs of Western New York’s volunteer fire service at the state level, according to FASNY. “I’m honored to be re-elected and to continue advocating for the men and women who volunteer their time, risk their safety and serve their communities across the state,” Pilecki said. “...
Post a Comment
Read Complete Article HERE>»

Many CUs Likely to Face New Operating Challenges "Michael Moebs"

04/08/2024 09:04 pm By Ray Birch LAKE FOREST, Ill.—The trend lines don’t lie: Financial institutions charging high overdraft fees will likely face operating challenges in the near future and may even be forced to merge if they don’t follow the market trend of lowering their OD charge. Michael Moebs, economist and chairman of Moebs $ervices, is offering that forecast following his company’s new overdraft study, which has found overall net OD revenue for 2023 was down 5.7%, with banks dipping by 8.1% to $31.4 billion, thrifts falling by 28.6%. and credit unions actually increasing net revenue 2.2%. The study further reveals the m...
Post a Comment
Read Complete Article HERE>»