Regulatory Alert: HMDA Floor Holds

ALEXANDRIA, Va.-NCUA Chairman Dennis Dollar issued a Regulatory Alert last week notifying credit unions that the Federal Reserve Board had set the Home Mortgage Disclosure Act reporting threshold for 2003 at the same level as last year. Financial institutions, including credit unions, with assets in excess of $32 million at year-end 2002 will have to report HMDA-required data. According to CUNA data based on Sept. 2002 Call Report data, this would include 2,153 credit unions. Fourth quarter Call Report data is not yet available. The Fed adjusts the asset size exemption threshold annually in accordance with the consumer price index, which it said increased 1.27% for the 12-month period ending November 2002. NCUA’s letter suggests credit unions answer three questions to determine if HMDA data should be collected in 2003: 1. Did total assets exceed $32 million as of December 31, 2002? 2. Did the credit union have a home or branch office in a metropolitan statistical area on December 31, 2002? 3. During 2002, did the credit union originate at least one home purchase loan or refinancing of a home purchase loan secured by a first lien on a one-to-four-family dwelling? If the answer is `yes’ to all three questions, then HMDA data collection and reporting requirements apply, but if any one of the answers is `no,’ then the credit union is exempt from filing HMDA data. Credit unions required to collect HMDA data that have not received the data collection software from the Fed should contact the appropriate NCUA regional office, the Regulatory Alert recommended. Guidance is also available through the appropriate NCUA regional office or NCUA’s publications department.