HMDA 2019 Data Submissions and Requirements for 2020

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Submission of 2019 Home Mortgage Disclosure Act Data

Credit unions located in metropolitan areas that engage in certain types and volume of residential mortgage lending, and that had assets exceeding $46 million as of Dec. 31, 2018, must file a report this year on mortgage loan applications received during 2019. The filing is required under the Home Mortgage Disclosure Act HMDA, as implemented by the Consumer Financial Protection Bureau's (CFPB's) Regulation C.

To determine if your credit union must submit HMDA data for calendar year 2019 activity, please review the 2019 HMDA Institutional Coverage Chart.

HMDA Data Collection Requirements for Calendar Year 2020

If your credit union makes residential mortgage loans and meets all four criteria outlined below, you must comply with Regulation C and are required to collect HMDA data associated with mortgage loan applications processed during 2020, if:

1. Your credit union’s total assets as of Dec. 31, 2019, exceeded $47 million;
2. Your credit union had a home or branch office in a Metropolitan Statistical Area on Dec. 31, 2019;
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 2019; and
4. Your credit union originated at least 25 closed-end mortgage loans in each of the two preceding calendar years (2018 and 2019) or 500 open-end lines of credit in each of the two preceding calendar years (2018 and 2019).

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