March 1 HMDA filing date coming up

(Feb. 12, 2021) Credit unions required to file reports on home mortgage loan applications made last year have until March 1 to do so, NCUA reminded this week in a Regulatory Alert.

In the alert (21-RA-03), the agency said all federally insured credit unions with assets of more than $47 million in assets as of Dec. 31, 2019, must file the application reports as required under the Home Mortgage Disclosure Act (HMDA), and implemented by the Consumer Financial Protection Bureau’s (CFPB’s) Regulation C.

There are some limiting provisions for reporting under the rule, the agency pointed out. For example, the closed-end mortgage loan threshold increased from 25 to 100 effective July 1, 2020. “Credit unions that originated fewer than 100 covered closed-end mortgage loans in 2018 or 2019 are not required to report any closed-end mortgage loan information for 2020,” the agency wrote, noting that Section 1003.3(c) of Regulation C lists excluded (not covered) transactions.

All data submitted, the agency said, must be done through the Federal Financial Institution Examination Council’s (FFIEC) HMDA Platform and that no other submission methods are permitted. An authorized representative of the credit union with knowledge of the data submitted must certify to the accuracy and completeness of the data submitted, the agency noted.

LINK:
Submission of 2020 Home Mortgage Disclosure Act Data (NCUA Regulatory Alert, 21-RA-03)