Dear Boards of Directors and CEOs:
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).1
HMDA Data Collection Requirements for Calendar Year 2024
Regulation C requires you to collect HMDA data associated with mortgage loan applications processed during 2024 if:
- Your credit union’s total assets as of December 31, 2023, exceeded $56 million;2
- Your credit union had a home or branch office in a Metropolitan Statistical Area on December 31, 2023;
- 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 2023; and
- Your credit union originated at least 25 covered closed-end mortgage loans in each of the 2 preceding calendar years (2022 and 2023) or at least 200 covered open-end lines of credit in each of the 2 preceding calendar years (2022 and 2023).
If your credit union meets all four criteria, you must collect HMDA data during calendar year 2024 and submit the data to the CFPB no later than March 3, 2025.3If your credit union does not meet all four criteria, you are exempt from filing HMDA data for mortgage loan applications processed in calendar year 2024.
HMDA Data Partial Exemptions
Regulation C contains partial exemptions from HMDA’s requirements for certain transactions.
Regulation C provides that a credit union is not required to collect or report certain data points with respect to closed-end mortgage loans if the credit union originated fewer than 500 covered closed-end mortgage loans in each of the 2 preceding calendar years. Similarly, a credit union is not required to collect or report certain data points with respect to open-end lines of credit if the credit union originated fewer than 500 covered open-end lines of credit in each of the 2 preceding calendar years.
Section 1003.3(c) of Regulation C lists excluded (not covered) transactions.
The table below provides partial exemption examples.
| Credit Union | Loan Type | Originations During Calendar Year2022 | Originations During Calendar Year 2023 | Partial Exemption In 2024 |
|---|---|---|---|---|
| A | Closed-end mortgage loans Open-end lines of credit | 425 500 | 450 525 | Only closed-end mortgage loans are exempt |
| B | Closed-end mortgage loans Open-end lines of credit | 475 400 | 500 425 | Only open-end lines of credit are exempt |
| C | Closed-end mortgage loans Open-end lines of credit | 525 600 | 550 625 | Neither exemption applies |
As the table indicates, the partial exemption for closed-end mortgage loans and the partial exemption for open-end lines of credit operate independently of one another. Thus, a credit union may rely on one partial exemption but not the other.
There are 48 data points required by Regulation C. The regulation specifies that 26 of these data points are not required to be collected and reported if a transaction qualifies for a partial exemption. The regulation also specifies that 22 of these data points must be collected and reported even if a transaction qualifies for a partial exemption. Appendix F (Partial Exemptions Charts) in the 2023 A Guide to HMDA Reporting: Getting It Right! outlines the 26 data points covered by the partial exemptions and the 22 data points not covered by the partial exemptions.
As illustrated in the table above, in 2024, Credit Union A would only be required to collect and report the 22 non-exempt data points, but not the 26 exempt data points, for its closed-end mortgage loans and applications. Credit Union A would, however, be required to collect and report all 48 data points for its open-end lines of credit loans and applications.
In 2024, Credit Union B would only be required to collect and report the 22 non-exempt data points, but not the 26 exempt data points, for its open-end lines of credit loans and applications. Credit Union B would, however, be required to collect and report all 48 data points for its closed-end mortgage loans and applications.
In 2024, Credit Union C would be required to collect and report all 48 data points for both its closed-end mortgage loans and applications and its open-end lines of credit loans and applications.
Please note that a credit union may voluntarily report any or all of the 26 exempt data points. However, if a credit union opts to report an exempt data point voluntarily, it must report all data fields that are part of that data point.
Submission of 2023 HMDA Data
As a reminder, credit unions subject to HMDA data collection requirements in calendar year 2023 must submit their loan/application register data to the CFPB using the HMDA Platform by March 1, 2024. To determine if your credit union must submit HMDA data for calendar year 2023 activity, please review the 2023 HMDA Institutional Coverage Chart.
The NCUA expects every credit union required to report 2023 HMDA data to submit its file to the CFPB by the March 1, 2024, deadline. Credit unions appearing on a delinquent filers list could become subject to civil money penalty assessments.
Additional Information
Additional resources, including the Filing Instructions Guide for HMDA data collected in 2023, can be found on the Resources for HMDA filers page on the CFPB’s website. Technical questions about reporting HMDA data should be directed to hmdahelp@cfpb.gov.
If you have questions about the information in this Regulatory Alert, please contact the NCUA’s Office of Consumer Financial Protection at 703.518.1140 or ComplianceMail@ncua.gov. You can also contact your NCUA regional office or your state supervisory authority.
