HMDA Data Collection Requirements for 2021; Due March 1, 2022


If your credit union makes residential mortgage loans and meets all four criteria outlined below, you must comply with the Consumer Financial Protection Bureau’s (CFPB) Regulation C, which implements the Home Mortgage Disclosure Act (HMDA).

Regulation C requires you to collect HMDA data associated with mortgage loan applications processed during 2021 if:

  1. Your credit union’s total assets as of Dec, 31, 2020, exceeded $48 million;
  2. Your credit union had a home or branch office in a Metropolitan Statistical Area on Dec. 31, 2020;
  3. Your 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 2020; and
  4. Your credit union originated at least 100 covered closed-end mortgage loans in each of the two preceding calendar years (2019 and 2020) or at least 500 covered open-end lines of credit in each of the two preceding calendar years (2019 and 2020).

If your credit union meets all four criteria, you must collect HMDA data during calendar year 2021 and submit the data to the CFPB no later than March 1, 2022.

If your credit union does not meet all four criteria, you are exempt from filing HMDA data for mortgage loan applications processed in calendar year 2021.

Click here for the Regulatory Alert.

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