Agency clarifies S. 2155 HMDA changes

Compliance: NCUA alerts cover 2021-22 HMDA requirements

February 7, 2022

NCUA issued two Regulatory Alerts on credit union requirements for submission of Home Mortgage Disclosure Act (HMDA) data. One (22-RA-02) covers submission of 2021 HMDA data, which is due to NCUA 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 $48 million as of Dec 31, 2020, must file a report this year on mortgage loan applications received during 2021.

The Consumer Financial Protection Bureau’s HMDA Institutional Coverage Chart contains information on qualifying credit union activity.

Credit unions must submit their HMDA data using the HMDA Platform. No other submission methods are permitted.

Credit unions will use 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.

The alert also contains links to the Filing Instructions Guide and the Resources for HMDA filers.

The other alert (22-RA-01) covers HMDA collection requirements for 2022.

Regulation C requires credit unions to collect HMDA data associated with mortgage loan applications processed during 2022, if:

  • The credit union’s total assets as of Dec. 31, 2021, exceeded $50 million;
  • The credit union had a home or branch office in a Metropolitan Statistical Area on Dec. 31, 2021;
  • 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 2021; and
  • The credit union originated at least 100 covered closed-end mortgage loans in each of the two preceding calendar years (2020 and 2021) or at least 200 covered open-end lines of credit in each of the two preceding calendar years (2020 and 2021).3

Credit unions meeting these criteria must collect HMDA data during calendar year 2022 and submit the data to the Consumer Financial Protection Bureau no later than March 1, 2023.