HMDA News: 2021 and 2022 Data Collection and Submission Requirements


The National Credit Union Administration (NCUA) issued two separate regulatory alerts pertaining to Home Mortgage Disclosure Act (HMDA) data collection and submission requirements for 2021 and 2022.

Submission of 2021 HMDA Data

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.

Credit unions subject to HMDA requirements in calendar year 2021 must submit loan/application register data to the Consumer Financial Protection Bureau (CFPB) by March 1, 2022.

To determine if a credit union must submit HMDA data for calendar year 2021 activity, please review the 2021 HMDA Institutional Coverage Chart.

Read the 22-RA-2 Regulatory Alert here.

HMDA Data Collection Requirements for 2022

If a credit union meets all four criteria listed below, it must collect HMDA data during calendar year 2022 and submit the data to the CFPB no later than March 1, 2023.

  1. A credit union’s total assets as of December 31, 2021, exceeded $50 million;
  2. A credit union had a home or branch office in a Metropolitan Statistical Area on Dec. 31, 2021;
  3. A 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
  4. A 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).

If a credit union does not meet all four criteria, it is exempt from filing HMDA data for mortgage loan applications processed in calendar year 2022.

Read the 22-RA-1 Regulatory Alert here.

Pin It