NCUA releases 2014, 2015 HMDA requirements guidance

February 27, 2015

ALEXANDRIA, Va. (3/2/15)--Guidance on Home Mortgage Disclosure Act (HMDA) data for 2014 and 2015 has been issued by the National Credit Union Administration. HMDA, which falls under the authority of the Consumer Financial Protection Bureau, requires lending institutions to report public loan data.

Credit unions subject to HMDA requirements in 2014 must submit loan/application register (LAR) data to the Federal Reserve board no later than today.  Credit unions located in metropolitan areas that engage in certain types of residential lending that had more than $43 million in assets as of Dec. 31, 2013, must file submit this data.

According to the NCUA, it will be provided a list of credit unions that do not submit the required data after March 2, and those institutions could be subject to civil money penalties.

Data may be submitted via paper form by credit unions with 25 or fewer entries on their LAR, all others must submit an automated form via Web or email.

Credit unions must collect HMDA data associated with mortgage loan applications processed during 2015 if they meet the following criteria:

  • Total assets exceeding $44 million, as of Dec. 31, 2014;
  • Existence of a home or branch office in a Metropolitan Statistical Area on Dec. 31, 2014; and
  • During 2014, 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-family dwelling.

Credit unions that do not meet all three criteria are exempt from filing HMDA data for calendar year 2015.

Data collected by credit unions for 2015 is due to the Federal Reserve board by March 1, 2016.