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#2248789 - 02/05/21 08:28 PM HMDA Exempt?
NSF, CRCM Offline
Gold Star
NSF, CRCM
Joined: Apr 2013
Posts: 410
VA
I just wanted to double check myself. For 2020 we only originated 73 closed-end covered loans and are below the threshold for open-end lines as well. Which means we do not have to submit HMDA data before 3/1/2021 and that we will not need to collect HMDA data for 2021 and 2022 for submittal. Is this interpretation correct?
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#2248814 - 02/08/21 12:48 PM Re: HMDA Exempt? NSF, CRCM
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,572
If you only originated 73 closed-end covered loans in 2020, you won't be reporting for 2021 or 2022. To determine if you are required to report for 2020 (submission due 3/1/2021), you need to look at your originations in each of the two preceding calendar year, which would be 2018 and 2019. How many closed-end covered loans did you have in each of those two years?

Here is a coverage flow chart effective 7/1/20 through 12/31/21: https://files.consumerfinance.gov/f/documents/cfpb_2020-hmda-institutional-coverage.pdf
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#2248818 - 02/08/21 01:55 PM Re: HMDA Exempt? NSF, CRCM
NSF, CRCM Offline
Gold Star
NSF, CRCM
Joined: Apr 2013
Posts: 410
VA
Oh okay that does make sense. Since we had 145 closed-end covered loans for 2018 and 109 for 2019 then we would report for 2020, but since we only had 73 closed-end covered loans for 2020 we would be exempt from reporting 2021 and 2022 data.

For some reason no matter how many times I read that section of the regulation it would just not click with me.

Thanks for your help.
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#2249307 - 02/17/21 06:48 PM Re: HMDA Exempt? NSF, CRCM
cwscb Offline
Junior Member
Joined: Jan 2018
Posts: 30
In other words, if we originated 30 closed-end mortgages in 2018 but only 20 closed-end mortgages in 2019, then we do not need to report for year 2020? In year 2020, we originated less than 10 closed-end mortgages.

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#2249310 - 02/17/21 07:30 PM Re: HMDA Exempt? NSF, CRCM
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,572
The rules changed in July of 2020 that were effective for your 2020 submission (here in 2021). So, yes, you are correct that it appears that you don't need to submit closed-end HMDA for 2020 based on your 2018 and 2019 numbers. Based on your 2020 numbers, it also appears you won't be submitting for (at least) the next two years - 2021 and 2022.

The flowchart I shared above will help walk you through it.
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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#2249543 - 02/22/21 08:22 PM Re: HMDA Exempt? NSF, CRCM
cwscb Offline
Junior Member
Joined: Jan 2018
Posts: 30
Although we are exempt in filing, we are to prepare a letter to Re. HMDA Exemption for Year 2020 Submission. Where could I find the address we should be sending this letter to?

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#2249548 - 02/22/21 08:50 PM Re: HMDA Exempt? NSF, CRCM
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,215
Galveston, TX
Not sure - I have never heard of such a letter. Usually you just either file or you do not. Do you have any more information concerning it?
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#2249556 - 02/22/21 11:50 PM Re: HMDA Exempt? NSF, CRCM
cwscb Offline
Junior Member
Joined: Jan 2018
Posts: 30
Looking back at our records from previous years when we did not need to report HMDA, we sent the Federal Reserve Board a letter saying that we originated less than the certain amount of loans for that year's HMDA. Not quite sure if we still need to do this.

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#2253650 - 05/07/21 03:45 PM Re: HMDA Exempt? NSF, CRCM
Ohmyachinghead Offline
Junior Member
Joined: Sep 2015
Posts: 37
Oklahoma
We are now exempt from reporting. Are we required to renew the banks LEI?

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#2253664 - 05/07/21 08:02 PM Re: HMDA Exempt? NSF, CRCM
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,215
Galveston, TX
Do you sell any loans?
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#2253726 - 05/10/21 05:54 PM Re: HMDA Exempt? rlcarey
Ohmyachinghead Offline
Junior Member
Joined: Sep 2015
Posts: 37
Oklahoma
We do not sell loans

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#2253731 - 05/10/21 06:26 PM Re: HMDA Exempt? NSF, CRCM
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 77,215
Galveston, TX
Then I can think of no reason to continuing to register.
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