Read the Blog Post from the CFPB Here

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Treliant Takeaway:

Treliant knows the Home Mortgage Disclosure Act. If your institution needs assistance in gathering, scrubbing, or submitting your HMDA LAR, Treliant can help.


In September 2022, a court order vacated the 2020 Home Mortgage Disclosure Act (HMDA) Final Rule regarding the loan volume reporting threshold for closed-end mortgage loans. As a result, the threshold for reporting data on closed-end mortgage loans is now 25 loans in each of the two preceding calendar years, which is the threshold established by the 2015 HMDA Final Rule. The new threshold is a significant reduction from the 100-loan threshold set by the 2020 HMDA Final Rule.  The court decision did not affect the 2020 change to a permanent threshold for open-end line of credit at 200 in each of the two preceding years.

The CFPB stated in a December 6th blog post their intention to not initiate enforcement actions or cite HMDA violations for failures to report closed-end mortgage loan data collected in 2022, 2021, or 2020 that met Regulation C’s other coverage requirements and originated at least 25 closed-end mortgage loans in each of the two preceding calendar years but fewer than 100 closed-end mortgage loans in either or both of the two preceding calendar years.


Lorraine Faust

Lorraine Faust, a Senior Manager with Treliant, is a regulatory and compliance professional with over 25 years’ experience in the financial services industry. She has worked in small, mid-size, and large financial institutions in both internal audit and compliance. Knowledgeable in a wide range of consumer protection laws, Lorraine’s focus…