On 12/17/21, the OCC issued the revised interagency Home Mortgage Disclosure Act (HMDA) examination procedures for determining compliance with HMDA and its implementing regulations. The interagency procedures update the April 19, 2019, FFIEC interagency examination procedures for the Home Mortgage Disclosure Act.
Highlights of revision include the following:
The revised procedures address changes to the effective dates for banks that meet or exceed either the closed-end mortgage loans or the open-end lines of credit loan-volume threshold in each of the two preceding calendar years:
Effective July 1, 2020, a bank, savings association, or credit union that originated at least 100 closed-end mortgage loans in each of the two preceding calendar years, or originated at least 500 open-end lines of credit in each of the two preceding calendar years meets or exceeds the loan-volume threshold.
Effective January 1, 2022, when the temporary threshold of 500 open-end lines of credit expires, a bank, savings association, or credit union that originated at least 100 closed-end mortgage loans in each of the two preceding calendar years, or originated at least 200 open-end lines of credit in each of the two preceding calendar years meets or exceeds the loan-volume threshold.
The revised procedures also address changes to a partial exemption to apply to an application or covered loan (including a purchased covered loan). An eligible bank must meet the applicable loan-volume threshold:
A partial exemption applies to an eligible bank’s applications for, originations of, and purchases of closed-end mortgage loans if the bank originated fewer than 500 closed-end mortgage loans in each of the two preceding calendar years. When a bank determines whether it meets the loan-volume thresholds for a partial exemption, the bank does not count transactions excluded by 12 CFR 1003.3(c)(1) through (10) and (13).
A partial exemption applies to an eligible bank’s applications for, originations of, and purchases of open-end lines of credit if the bank originated fewer than 500 open-end lines of credit in each of the two preceding calendar years.
See the full bulletin here.
Access the revised HMDA booklet here.
