Regulatory Alerts2023-01-31
Changes to Home Mortgage Disclosure Act (HMDA) Loan Volume Reporting Threshold for Closed-end Mortgage Loans
The Federal Reserve issued this letter to address the reinstatement of the lower HMDA reporting threshold for closed-end mortgage loans following a court vacatur of the CFPB's 2020 rule. The Board announced it will not cite HMDA violations or take enforcement action against supervised institutions that originated between 25 and 100 closed-end loans in either of the two preceding calendar years for data collected in 2020, 2021, or 2022. This enforcement discretion allows affected institutions time to adjust their policies, procedures, and systems to comply with the regulatory requirement of reporting data for institutions originating at least 25 such loans annually.
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