On January 31, 2023, the Federal Reserve Board issued a letter to institutions supervised by the Federal Reserve regarding the changes to home mortgage disclosure act (HMDA) loan volume reporting threshold for closed-end mortgage loans. The letter addresses the impact on financial institutions supervised by the Federal Reserve of recent changes as a result of litigation related to the HMDA reporting threshold for closed-end mortgage loans.
In December 2022, the CFPB published a technical amendment updating the Code of Federal Regulations to reflect a reporting threshold of 25 closed-end mortgage loans in each of the two preceding calendar years. Like the CFPB’s stance, the Board of Governors of the Federal Reserve System recognizes that financial institutions affected by the change to the HMDA reporting threshold for closed-end mortgage loans may need time to implement or adjust policies and procedures, systems, and operations to come into compliance with their reporting obligations. The letter serves as notice that the Board does not intend to cite HMDA violations or take enforcement action for not collecting or reporting closed-end mortgage loan data originated in 2022, 2021, or 2020 by Federal Reserve-supervised financial institutions that meet Regulation C's other coverage requirements and originated at least 25 closed-end mortgage loans in each of the two preceding calendar years but fewer than 100 closed-end mortgage loans in either or both of the two preceding calendar years.
Read the FRB’s letter here.