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LET THE ANALYSIS BEGIN

Modified Home Mortgage Disclosure Act (HMDA) data for 2022 submissions from 4,394 filers are now available on the Federal Financial Institutions Examination Council (FFIEC) website. A downloadable modified (to protect consumer privacy) LAR file is available for every financial institution that has completed a HMDA data submission for 2022. The data is typically used to: Verify the data you submitted a few weeks ago is properly presented. Compare your institution’s data to the data from […]

FINAL THRESHOLD UPDATE FOR 2022

I bet you thought that you were all wrapped up on your compliance news for 2022, huh? Well…not so fast! On December 28, 2022, The CFPB released the final HMDA threshold and the remaining Regulation Z thresholds. The HMDA threshold was increased from $50 million in 2022 to $54 million in 2023. The HPML Small Creditor Threshold was increased from $2.336 billion to $2.537 billion in 2023. The HPML Intermediate Creditor Threshold was increased from […]

Are you one of the 1,700 new HMDA reporting institutions? Here’s where to start.

On December 6, 2022, the CFPB issued a Notice rescinding its 2020 Home Mortgage Disclosure Act (HMDA) Final Rule changing the loan volume reporting threshold for closed-end mortgage loans.  This was in response to a ruling by the United States District Court for the District of Columbia, in September of this year which stated that the CFPB did not have the authority to change the original reporting threshold from 25 to 100. In the notice the CFPB […]

CFPB Rescinds its 2020 HMDA Threshold Ruling

Yesterday, the CFPB issued a Notice rescinding its 2020, Home Mortgage Disclosure Act (HMDA) Final Rule changing the loan volume reporting threshold for closed-end mortgage loans.  This comes on the heels of a ruling by the United States District Court for the District of Columbia, in September of this year.  The ruling stated the CFPB did not have the authority to change the original reporting threshold from 25 to 100. The April 2020, the CFPB’s […]

DC District Court Rolls Back HMDA Threshold

On September 23, 2022, the United States District Court for the District of Columbia issued a Memorandum Opinion that reversed a section of Regulation C, the Consumer Financial Protection Bureau’s (CFPB) regulation which implements the Home Mortgage Disclosure Act (HMDA).   The April 2020 final HMDA rule increased the reporting threshold for closed-end mortgage loans from 25 covered loans originated in each of the prior two years to 100 covered loans originated in each of […]