ALEXANDRIA, Va.–NCUA has sent a Regulatory Alert to credit unions as a reminder that if they make residential mortgage loans and meet four criteria, they must comply with the Consumer Financial Protection Bureau’s Regulation C, which implements the Home Mortgage Disclosure Act (HMDA).
Regulation C requires a credit union to collect HMDA data associated with mortgage loan applications processed during 2024 if:
- The credit union’s total assets as of Dec. 31, 2023 exceeded $56 million;
- A credit union had a home or branch office in a Metropolitan Statistical Area on Dec. 31, 2023
- A 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
- A 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).
The Deadline
“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,” NCUA said. “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.”
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