Dear Board of Directors and Chief Executive Officer:
If your credit union makes residential mortgage loans and meets all three criteria outlined below, you must comply with the Consumer Financial Protection Bureau’s (CFPB) Regulation C, which implements the Home Mortgage Disclosure Act (HMDA).1
Regulation C requires you to collect HMDA data associated with mortgage loan applications processed during 2016, if:
- Your credit union’s total assets as of December 31, 2015, exceeded $44 million;2
- Your credit union had a home or branch office in a Metropolitan Statistical Area on December 31, 2015; and
- During 2015, 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.
If your credit union meets all three criteria, you must collect HMDA data during calendar year 2016 and submit the data to the Federal Reserve Board no later than March 1, 2017.
If your credit union does not meet all three criteria, you are exempt from filing HMDA data for calendar year 2016.
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 Protection at (703) 518-1140 or ComplianceMail@ncua.gov.
1 12 U.S.C. 2801-2810; 12 CFR Part 1003.
2 The asset-size exemption threshold remains unchanged from the previous year. See 80 FR 79673 (December 23, 2015).