A reminder that credit unions must comply with rules governing disclosure in mortgage loans, particularly those meeting four criteria, is outlined by their federal regulator in a “regulatory alert” issued Wednesday.
The National Credit Union Administration (NCUA), in its regulatory alert 22-RA-01 (Home Mortgage Disclosure Act Data Collection Requirements for Calendar Year 2022), said credit unions making the home loans and meeting the four criteria must comply with the Consumer Financial Protection Bureau’s (CFPB) Regulation C, which implements the Home Mortgage Disclosure Act (HMDA).
The agency stated that the rule requires credit unions (and other financial institutions) to collect HMDA data associated with mortgage loan applications processed during 2022 if the credit union:
- Had total assets of more than $50 million as of Dec. 31, 2021;
- Had a home or branch office in a metropolitan statistical area on Dec. 31, 2021;
- Created 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 unit dwelling during 2021; and
- Originated at least 100 covered closed-end mortgage loans in each of the two preceding calendar years (2020 and 2021) or at least 200 covered open-end lines of credit in each of the two preceding calendar years (2020 and 2021).