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HMDA 2023 Coverage Threshold Test

Closed-End Mortgage Loan-Volume Reporting Threshold Effective December 6, 2022

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.

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

•    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

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

 

Worksheet Completed By: __________________________________________    Date: ______________

 

Verified By: ______________________________________________________    Date: ______________
 

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.

Additional guidance:

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

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January 31, 2023 - Webinar: Anti-Money Laundering Act: Update, & Lessons Learned     

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