The FDIC issued a Financial Institution Letter on changes to the loan-origination threshold for reporting Home Mortgage Disclosure Act data on closed-end mortgage loans following a recent court decision. The OCC previously issued a similar bulletin.
Details: The FIL notes that the threshold for reporting is now 25 closed-end mortgage loans originated in each of the two preceding calendar years, down from the 100-loan threshold set by the 2020 HMDA rule.
Background: A U.S. district court in September vacated the higher loan-volume threshold. The Consumer Financial Protection Bureau in December amended its regulations and released updated enforcement guidance.
ICBA Position: ICBA is cautioning policymakers that the regulatory burden on community banks that were previously exempt from HMDA reporting outweighs any benefits to the agency and consumer groups of accessing the aggregate data points.
