Compliance: HMDA data must be submitted by March 1

February 16, 2021

NCUA’s latest Regulatory Alert (21-RA-03) notes that credit unions subject to Home Mortgage Disclosure Act (HMDA) requirements in calendar year 2020 must submit loan/application register data to the Consumer Financial Protection Bureau (CFPB) by March 1.

Credit unions located in metropolitan areas that engage in certain types and volume of residential mortgage lending, and that had assets exceeding $47 million as of Dec. 31, 2019, must file a report this year on mortgage loan applications received during 2020.

NCUA’s 2020 HMDA Institutional Coverage Chart has information for credit unions to determine if they must submit calendar year 2020 HMDA data.

Credit unions must submit their HMDA data using the HMDA Platform to upload their loan/application register (LAR) data, review edits, certify the accuracy and completeness of the data, and submit data for the filing year.

Credit unions must address all edits prior to submitting their HMDA data. The edit report will be web-based.

Additional resources, including the Filing Instructions Guide for HMDA data collected in 2020, can be found on the Resources for HMDA filers page on the Consumer Financial Protection Bureau’s website.

NCUA expects every credit union required to report 2020 HMDA data to submit its file to the CFPB by the March 1 deadline. Credit unions appearing on a delinquent filers list could become subject to civil money penalty assessments.