NCUA Issues HMDA Regulatory Alert for 2024
The alert covers which credit unions need to comply with requirements under the CFPB’s Reg. C.
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:
- Your credit union’s total assets as of Dec. 31, 2023, exceeded $56 million;
- Your credit union had a home or branch office in a Metropolitan Statistical Area on Dec. 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 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.
The regulatory alert pointed to several examples of data reporting exemptions for credit unions. For instance, “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 two preceding calendar years.”
The NCUA provided partial exemption examples in the chart below.
Thursday’s regulatory alert explained “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.”
The NCUA advised credit unions with questions about the alert should contact the agency’s Office of Consumer Financial Protection.