Dear Board of Directors and Chief Executive Officer:
If your credit union makes residential mortgage loans and meets all four criteria outlined below, you must comply with the Consumer Financial Protection Bureau’s Regulation C, which implements the Home Mortgage Disclosure Act.1
Regulation C requires you to collect HMDA data associated with mortgage loan applications processed during 2017, if:
- Your credit union’s total assets as of December 31, 2016, exceeded $44 million;2
- Your credit union had a home or branch office in a Metropolitan Statistical Area on December 31, 2016;
- 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-family dwelling during 2016; and
- Your credit union originated at least 25 home purchase loans, including refinancings of home purchase loans in each of the two preceding calendar years (2015 and 2016).3
If your credit union meets all four criteria, you must collect HMDA data during calendar year 2017 and submit the data to the Consumer Financial Protection Bureau no later than March 1, 2018.
If your credit union does not meet all four criteria, you are exempt from filing HMDA data for calendar year 2017.
For more information about this Regulatory Alert or HMDA filing, please visit NCUA’s Consumer Compliance Regulatory Resources webpage, or contact NCUA’s Office of Consumer Financial Protection and Access at (703) 518-1140 or ComplianceMail@ncua.gov.
If you have further questions, please contact your regional NCUA office or state supervisory authority.
Sincerely,
Footnotes
[1] 12 U.S.C. 2801-2810; 12 CFR Part 1003.
[2] The asset-size exemption threshold remains unchanged from the previous year. See 81 FR 93650 (December 21, 2016).
[3] The criteria was added for 2017 to better achieve HMDA’s purposes and to reduce unnecessary burden on financial institutions. See 80 FR 66128 (October 28, 2015).