Regulatory Alert Summary

Prepared by NASCUS Legislative & Regulatory Affairs Department

January 2016

16-RA-01  Home Mortgage Disclosure Act (HMDA) Data Collection Requirements for Calendar Year 2016

NCUA published Regulatory Alert 16-RA-01 to advise credit unions of the Home Mortgage Disclosure Act (HMDA) data collection requirements for 2016.  HMDA is implemented by the Consumer Financial Protection Bureau’s (CFPB) Regulation C and is applicable to all credit unions that meet the following criteria:

  1. The credit union’s total assets as of Dec. 31, 2015, exceeded $44 million.  Note: the asset- size exemption threshold remains the unchanged from the previous year;
  2. The credit union had a home or branch office in a Metropolitan Statistical Area (MSA) on December 31, 2015; and
  3. During 2015, the credit union originated at least one home purchase loan (other than temporary financing such as a construction loan) or refinanced a home purchase loan, secured by a first lien on a one-to-four family dwelling.

A credit union that meets all three criteria is required to collect HMDA data during calendar year 2016 and submit the data to the Federal Reserve Board no later than March 1, 2017.