Compliance: HMDA data collection requirements for calendar year 2023

NCUA issued a Regulatory Alert (23-RA-02) on Home Mortgage Disclosure Act (HMDA) data collection requirements for the calendar year 2023. 

Credit unions that meet all four criteria must collect HMDA data during calendar year 2023 and submit the data to the CFPB no later than March 1, 2024.

Regulation C requires credit unions to collect HMDA data associated with mortgage loan applications processed during 2023 if the credit union:

1. Total assets exceeded $54 million as of Dec. 31, 2022;
2. Had a home or branch office in a Metropolitan Statistical Area on Dec. 31, 2022;
3. 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;
4. 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).

Credit unions that do not meet all four criteria are exempt from filing HMDA data for mortgage loan applications processed in calendar year 2023.

The alert also contains a list and table of HMDA data partial exemptions.