2020 HMDA Reporting Threshold Changes

The Consumer Financial Protection Bureau recently issued a final Home Mortgage Disclosure Act (HMDA) rule that increases the threshold for required reporting of closed-end mortgage loans and dwelling-secured open-end lines of credit. It is applicable to depository and non-depository institutions.

Closed-End Mortgage Loans

If an institution originated at least 25 closed-end loans in both 2018 and 2019, then as of January 1, 2020 the institution has to collect, record and report HMDA data for calendar year 2020. 

However, as of July 1, 2020, if an institution originated fewer than 100 closed-end loans in either 2018 or 2019, then it is a newly excluded institution (NEI) subject to these revised HMDA reporting guidelines:

  • NEI may cease the collection of data for HMDA purposes beginning on July 1, 2020. However, ECOA and Reg B require data collection for mortgage loans for the purchase or refinancing the consumer’s principal residence, including applicant’s ethnicity, race, sex, marital status and age.
  • NEI must record Q1 2020 closed-end mortgage loan data on loan application registers within 30 days after the end of the first quarter, but will not be required to record Q2 2020 data.
  • NEI is not required to report any HMDA data for 2020, even the data that was collected and recorded for the first quarter. However, it may voluntarily report data for the entire year.

Open-End Lines of Credit

If an institution originated at least 100 dwelling-secured open-end lines of credit in each of the two prior years, then it must collect, record and report date by March 1 of the following calendar year.

However, as of January 1, 2022, the reporting threshold will increase from 100 to 200 originated dwelling-secured open-end lines of credit in each of the prior two years.

Click here to view a timeline of key dates. 


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