Revised guide for HMDA reporting reflects asset-size exemptions, other changes from last year

A revised guide to reporting of home mortgage terms was released Monday, the regulator of national banks said, reflecting changes in the asset-size exemption, and others, that went into effect Jan. 1.

The revised guide to Home Mortgage Disclosure Act (HMDA) reporting (formally, “A Guide to HMDA Reporting: Getting it Right!”) provides resources to help banks comply with HMDA and Regulation C, its implementing regulation, the Office of the Comptroller of the Currency (OCC) said.

The revised guide was issued by the Federal Financial Institutions Examination Council (FFIEC), the umbrella group for federal financial institution regulators for certain activities, including HMDA reporting.

At the start of the year, the changes for reporting HMDA data on closed-end mortgage loans (and, separately, for escrow accounts for higher-priced mortgage loans (HPMLs) became:

  • Institutions with assets of $56 million (up from $54 million) or less are exempt from HMDA data collection in 2024.
  • Creditors and their affiliates that regularly extended covered transactions secured by first liens and that have less than $2.640 billion in assets (up from $2.537 billion) are exempt from the Regulation Z requirement to establish an escrow accounts for HPMLs.
  • Banks and credit unions with assets of less than $11.835 billion (up from $11.374 billion) are exempt from the Reg C requirement to establish escrow accounts for HPMLs.

The revised guide, the OCC said, discusses such areas as institutions covered by Regulation C, transactions covered by Regulation C, information that covered institutions are required to collect, record, and report and requirements for reporting and disclosing data.

The 2024 revised version of the guide rescinds and replaces the 2023 HMDA reporting guide, the OCC said.

Home Mortgage Disclosure Act: FFIEC’s 2024 ‘A Guide to HMDA Reporting: Getting It Right!’