HMDA (Regulation C)

Question 1

What is HMDA?

Answer 1

This act requires certain lenders, based on asset size, location, and housing-related lending activity, to report data regarding its mortgage lending activity.

Question 2

What does HMDA stand for?

Answer 2

The Home Mortgage Disclosure Act (Regulation C)

Question 3

What information must be reported for every transaction?

Answer 3

• Loan number
• Date of application
• Type and purpose of loan
• Owner occupancy status
• Loan amount
• Type of action taken
• Location, by MSA (metropolitan statistical area), state, county, and census tract
• Race, ethnicity, and sex of applicant(s) and gross annual income
• Type of entity purchasing the loan, if sold on the secondary market within a year of consummation

Question 4

What type of dwellings are subject to HMDA?

Answer 4

• Vacation or second homes.
• Rental properties
• Individual condominiums or cooperative units
• Manufactured homes and mobile homes
• Depository institutions (that meet certain guidelines)

Question 5

What is a depository institution?

Answer 5

Commercial banks, thrifts, and credit unions

Question 6

What criteria must depository institutions meet to be subject to HMDA?

Answer 6

• Meet an annually-adjusted asset-size threshold established by the CFPB. For 2021, banks, credit unions, and other depository institutions with assets of $48 million or less as of December 31, 2020 are exempt.
• Originate at least one home purchase loan or the refinance of a home purchase loan in the preceding calendar year
• Conduct business as a federally-insured or -regulated institution (e.g., it is an FDIC bank or a Federal Reserve bank), or make federally-insured or -guaranteed loans (e.g., FHA loans or VA loans), or originate loans intended for sale to Fannie Mae or Freddie Mac, and
• Meet a loan-volume threshold. The uniform loan-volume threshold for depository and non-depository institutions is:
  1. The origination of at least 100 closed-end mortgage loans in either of the two preceding calendar years, or
  2. The origination of at least 500 open-end lines of credit in either of the two preceding calendar years