HMDA Threshold Raised By CFPB
100 Prior Loans is the New Threshold

Christopher DonovanBy:

April 17, 2020

By: Dennis H. Doss and Christopher J. Donovan

Doss Law, LLP

Very good news for small lenders and brokers.  On April 16, 2020, the CFPB raised the threshold for the number of residential mortgage loans that a lender must make before being subject to HMDA reporting.  Effective July 1, 2020, the new threshold will be raised from 25 to 100 with a two year look-back period.  In other words, starting July 1st, unless you made 100 or more closed-end residential mortgage loans in both of the prior two calendars years (2018 and 2019), you are no longer subject to HMDA data collection and reporting.  If you did not make 100 or more loans in both 2018 and 2019, you do not have to report activity in those years or the first half of 2020.  Here is a copy of the announcement.

CFPB Announcement

© Doss Law, LLP.  Attorney advertising materials.  These materials have been prepared for educational purposes only and are not legal advice.  This information is not intended to create an attorney-client relationship.  Consult a knowledgeable lawyer before implementing any of the ideas in this publication.

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