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Change to HMDA’s Closed-End Loan Reporting Threshold

23-RA-01 / February 2023
Change to HMDA’s Closed-End Loan Reporting Threshold
Federally Insured Credit Unions
Federally Insured Credit Unions
Change to HMDA’s Closed-End Loan Reporting Threshold

Dear Boards of Directors and Chief Executive Officers:

On September 23, 2022, the United States District Court for the District of Columbia issued an order vacating the portion of the Consumer Financial Protection Bureau’s (CFPB) 2020 Home Mortgage Disclosure Act (HMDA) Final Rule that amended the reporting threshold for closed-end mortgage loans. The decision means that the threshold for reporting data on closed-end mortgage loans is now 25 loans in each of the two preceding calendar years, which is the threshold established by the 2015 HMDA Final Rule, rather than the 100 loan threshold set by the 2020 HMDA Final Rule.

The NCUA recognizes that credit unions affected by this change may need time to implement or adjust policies, procedures, systems, and operations to achieve compliance with these reporting requirements. Accordingly, the NCUA intends to take a flexible supervisory and enforcement approach similar to the approach being taken by the CFPB, as communicated in its December 6, 2022 CFPB Blog post.

The NCUA will not initiate enforcement actions or cite HMDA violations for failures to report closed-end mortgage loan data collected in 2022, 2021, or 2020 for credit unions 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.

If you have questions about the information in this Regulatory Alert, please contact the NCUA’s Office of Consumer Financial Protection at 703.518.1140 or You can also contact your NCUA regional office or your state supervisory authority.



Todd M. Harper


Home Mortgage Disclosure Act (HMDA)
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