On April 16, 2020, the CFPB issued its final rule on data reporting thresholds under HMDA. The permanent threshold for collecting and reporting data about closed-end mortgage loans is 100 loans in either of the two proceeding calendar years effective July 1, 2020. The permanent threshold for open-end lines of credit is 200 effective January 1, 2022.
These tests are “separate” tests – so, if you only meet one of the thresholds, you would only report those transactions. For example, if you meet the requirement for reporting closed-end, but not open-end, you will report ONLY closed-end transactions.
- If an institution originated at least 100 closed-end mortgage loans in “each” of the two preceding calendar years AND meets the other criteria, they are required to report all closed-end applications.
- If an institution originated at least 500 open-end lines of credit in “each” of the two preceding calendar years AND meets the other criteria, they are required to report all open-end lines of credit. This threshold is reduced to 200 open-end lines of credit effective January 1, 2022.