NCUA Alert to Federally Insured CUs: HMDA Data Requirements

If your credit union makes residential mortgage loans and meets all four criteria outlined below, it must comply with the Consumer Financial Protection Bureau’s (CFPB) Regulation C.

This regulation implements the Home Mortgage Disclosure Act (HMDA), the National Credit Union Administration (NCUA) reminded credit unions this past week. You can view the NCUA’s announcement here.

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.
• 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.
• 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.

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.

To find out more about HMDA data partial exemptions, submission of 2023 HMDA data, and gather additional information and resources, click here.

Access the ‘Compliance Hotline’
Your League-member benefits include the Compliance Hotline — providing exclusive access to dedicated compliance experts:

• 844-731-6072
• CANV@viclarityus.com

Using the above phone number and email address, you can gain access to a knowledgeable team that’s ready to address all your credit union’s compliance inquiries — promptly and efficiently. With the Compliance Hotline, you can proactively respond to impromptu questions and issues by getting clarity and insight on technical topics that normally slow you down. We want to help you unlock the full potential of your League membership by leveraging the resources and support you need to navigate the complex world of compliance effortlessly. We’re ALWAYS just a phone call or email away!

Additionally, other League-member compliance resources include:

• ViClarity
• CU PolicyPro
• ComplySight
• InfoSight
• CU Store
• Record Retention Guide
• GRC Technology Solutions

For more information, email Lisa Quaranta.

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