HMDA ALERT! - Smaller Mortgage Producing Banks May HAVE to Comply in 2023
Due to a court case (which the CFPB apparently lost) the threshold for reporting 2023 HMDA data is MANDATORY for all banks with:
- At least 25 closed-end mortgage originations in 2021 and 2022 AND
- At least one branch in an MSA AND
- At least $50 million in assets (this is the 2022 number; the 2023 asset limit has not been announced.)
As a result, HMDA may be new to your institution. Or, if you were able to stop reporting for the last few years while the minimum was 100 originations, you may need to start reporting again beginning January 1, 2023.