What are the thresholds for reporting HMDA data?

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.