NCUA Reminds Credit Unions to Submit Home Mortgage Data

The National Credit Union Administration ("NCUA") reminded Boards of Directors and CEOs of federally insured credit unions of their compliance obligation to collect and submit home mortgage data under the Consumer Financial Protection Bureau’s Regulation C ("Home Mortgage Disclosure Act").

In a Supervisory Notice, the NCUA stated that a credit union that makes residential mortgages must submit 2024 HMDA data by March 3, 2025, if the credit union (i) had total assets exceeding $56 million as of December 31, 2023, (ii) had a home or branch office in a Metropolitan Statistical Area on December 31, 2023, (iii) had originated at least one home purchase loan or refinanced a home purchase loan, secured by a first lien on a one-to-four-unit dwelling during 2023 and (iv) had originated at least 25 covered closed-end mortgage loans in each of the two preceding calendar years (2022 and 2023) or at least 200 covered open-end lines of credit in each of the two preceding calendar years (2022 and 2023).

In the Notice, the NCUA stated that if the credit union did not meet the criteria, it would be exempt from filing HMDA data for mortgage loan applications processed in calendar year 2024. NCUA also reminded credit unions that are subject to the HMDA data collection requirements in calendar year 2023 to submit their loan/application register data to the CFPB by March 1, 2024. Further, NCUA provided information on the HMDA partial and full exemptions under the Act.