The National Credit Union Administration (NCUA) issued a regulatory alert concerning the Home Mortgage Disclosure Act (HMDA) data collection requirements for calendar year 2023. If a credit union makes residential mortgage loans and meets all four criteria outlined below, it must comply with the Consumer Financial Protection Bureau’s (CFPB) Regulation C, which implements the HMDA. Regulation C requires a credit union to collect HMDA data associated with mortgage loan applications processed during 2023 if:
- A credit union’s total assets as of December 31, 2022, exceeded $54 million;
- The credit union had a home or branch office in a Metropolitan Statistical Area on December 31, 2022;
- The 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 2022; and
- The credit union originated at least 25 covered closed-end mortgage loans in each of the two preceding calendar years (2021 and 2022) or at least 200 covered open-end lines of credit in each of the two preceding calendar years (2021 and 2022).
If the credit union meets all four criteria, it must collect HMDA data during calendar year 2023 and submit the data to the CFPB no later than March 1, 2024. If your credit union does not meet all four criteria, it is exempt from filing HMDA data for mortgage loan applications processed in calendar year 2023.
Section 1003.3(c) of Regulation C lists excluded (not covered) transactions from HMDA requirements. To view the full NCUA regulatory alert, please visit this link.