NCUA official seal NCUA official seal. Credit/NCUA

The NCUA published a regulatory alert Thursday for federal credit unions that make residential mortgage loans. The alert focuses on compliance aspects from the CFPB's Regulation C, which implements the Home Mortgage Disclosure Act (HMDA).

The regulatory alert, signed by NCUA Board Chairman Todd Harper, laid out the data collection requirements under Regulation C that must be reported with mortgage loan applications processed by credit unions in 2024. According to the alert, the requirements apply to credit unions if the following four criteria are true:

  1. Your credit union's total assets as of Dec. 31, 2023, exceeded $56 million;
  2. Your credit union had a home or branch office in a Metropolitan Statistical Area on Dec. 31, 2023;
  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 2023; and
  4. Your credit union originated at least 25 covered closed-end mortgage loans in each of the two preceding calendar years (2022 and 2023) or at least 200 covered open-end lines of credit in each of the two 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. 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 2024," the alert stated.

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Editor-in-Chief at CU Times. To connect, email at [email protected]. As Editor-in-Chief of CU Times since 2016, Michael Ogden has led the editorial team in all aspects of content strategy and execution, including the creation of the publication’s exclusive and proprietary research database of the credit union industry’s economic landscape. Under Michael’s leadership, CU Times has successfully shifted to an all-digital editorial product with new focuses on the payments, fraud, lending and regulatory beats. Most recently, he introduced a data-focused editorial product for subscribers that breaks down credit union issues into hard data, allowing for a deeper and more factual narrative for readers. In 2024, he launched the "Shared Accounts With CU Times" podcast, which offers a fresh, inside-the-newsroom perspective through interviews with leaders from the credit union industry and the regulatory world. He dives into pressing credit union issues, while revealing the personalities working behind-the-scenes to push the credit union world forward. His background includes years as a radio and TV anchor/reporter and a public relations and digital/social media manager, where he covered the food and music industries, as well as cooperatives and credit unions. Over the years, he has launched numerous exclusive video and podcast series, including a successful series of interactive backstage interviews with musicians at music festivals, showcasing his social media and live streaming production skills.

Regulatory & Compliance