CLARIFICATION OF REVISED HMDA CLOSED-END THRESHOLD

As of January 1, 2020 the threshold for reporting closed-end loans for purposes of HMDA was 25 loans. As announced last Friday, on July 1, 2020 the threshold increases to 100 closed-end loans. As a result, institutions that originate:

  • Fewer than 25 closed-end loans continue to be exempt from reporting closed-end loans for HMDA;
  • 25 or more, but fewer than 100, closed-end loans become exempt from reporting closed-end loans for HMDA effective July 1, 2020 (More detail below.); and
  • 100 or more closed-end loans continue to report closed-end loans.

Impact During 2020

If as of December 31, 2019 your institution, in each of the two preceding calendar years (2018 and 2019), originated at least 25 closed-end mortgage loans that are not excluded from this part pursuant to § 1003.3(c)(1) through (10), then HMDA data collection is required for those loans until July 1, 2020.

  • A newly excluded institution, those subject to HMDA’s closed-end requirements as of January 1, 2020 because it originated at least 25 closed-end mortgage loans in 2018 and 2019 and meets all of the other requirements under § 1003.2(g), but no longer subject to HMDA’s closed-end requirements as of July 1, 2020 because it originated fewer than 100 closed-end mortgage loans during 2018 or 2019, are relieved of the obligation to collect, record, and report data for their 2020 closed-end mortgage loans effective July 1, 2020.
  • A newly excluded institutions may cease collecting 2020 data for closed-end mortgage loans as of July 1, 2020.
  • Pursuant to § 1003.4(f), newly excluded institutions must still record data on a loan/application register for the first quarter of 2020 by 30 calendar days after the end of the first quarter. They will not, however, be required to record closed-end data for the second quarter of 2020 because the deadline under § 1003.4(f) for recording such data falls after July 1, 2020.
  • Because newly excluded institutions collecting HMDA data in 2020 would not otherwise report those data until early 2021, the final rule also relieves newly excluded institutions of the obligation to report by March 1, 2021 data collected in 2020 on closed-end mortgage loans (including closed-end data collected in 2020 before July 1, 2020).

Impact During 2021

If as of December 31, 2020 your institution, in each of the two preceding calendar years (2019 and 2020), originated at least 100 closed-end mortgage loans that are not excluded from this part pursuant to § 1003.3(c)(1) through (10), it must collect HMDA data for closed-end loans for 2021.

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