HMDA 2023 Coverage Threshold Test
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Closed-End Mortgage Loan-Volume Reporting Threshold Effective December 6, 2022

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Purpose: To determine if the institution meets the revised HMDA reporting threshold of 25 closed-end loans announced by the CFPB on December 6, 2022.

Volume is based upon each of the two preceding calendar years (2021 & 2022).
 

Consumer Loans: Count all consumer purpose, dwelling secured loans: purchase, refinance, cash-out refinance, home improvement, and other.​

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Note:

•    Do not include lines of credit (Lines of credit are a different threshold)
•    Do not include applications that are not originated
 

Conclusion:
Did the institution originate fewer than 25 closed-end loans in 2021?                  Yes        No
Did the institution originate fewer than 25 closed-end loans in 2022?                  Yes        No

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•    Note:  A “Yes” answer to either the 2021 or 2022 question, would exempt the institution from 2023 reporting based upon the revised threshold announced by the CFPB on December 6, 2022.

 

Note:  A “Yes” answer to either the 2021 or 2022 question, would exempt the institution from 2023 reporting based upon the revised threshold announced by the CFPB on December 6, 2022

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Is the institution required to collect HMDA data beginning 1/1/2023?        Yes        No

 

Worksheet Completed By: __________________________________________    Date: ______________

 

Verified By: ______________________________________________________    Date: ______________
 

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Dwelling is a residential structure. There is no requirement that the structure be attached to real property or that it be the applicant’s or borrower’s residence. Examples of dwellings include:

• Principal residences;

• Second homes or vacation homes;

• Investment properties;

• Residential structures attached to real property;

• Detached residential structures;

• Individual condominium or cooperative units;

• Manufactured Homes (generally bear a HUD Certification Label and data plate) or other factory-built homes; and

• Multifamily residential structures or communities, such as apartment building, condominium complexes, cooperative buildings, or housing complexes.

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Additional guidance:

• Regulation B, 1003 https://www.consumerfinance.gov/rules-policy/regulations/1003/1/

  • 1003.2(d) Closed-end mortgage loan definition

• Small Entity Compliance Guide https://files.consumerfinance.gov/f/documents/cfpb_hmda_small-entity-compliance-guide_2021-04.pdf

  • 2.1 Institutional coverage

  • 4.1.1.2 Secured by a lien on a dwelling

  • 4.1.2 Excluded transactions

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Reminder of other criteria that must be satisfied to be a REQUIRED HMDA reporter.

• MSA – On the preceding December 31, did the institution have a home or branch office in a Metropolitan Statistical Area (MSA)?

• Asset Size as of December 31  must be greater than the following for both 2021 and 2022:

  • 2021 $50,000

  • 2022 Not yet released as of December 8, 2022. Typically, this number is released around the 20th of December and is posted here: https://www.consumerfinance.gov/rules-policy/final-rules/home-mortgage-disclosure-regulation-c-adjustment-asset-size-exemption-threshold/