So I need to be set straight. Under the new threshold limits for reporting closed end mortgages, I've seen the words "either" and both" used in connection with the 100 originated closed end mortgages for 2018 and 2019.

So if a financial institution reported the following number of originated closed end mortgages: 2018 = 75 and 2019 = 84. they do NOT have to report closed end mortgages to HMDA as of July 1, 2020.

BUT

If 2018 = 103 and 2019 = 95.....????

Thanks!!

Correct.


Exempt for at least two more years.

You must have 2 consecutive years of 100 or more closed-end loans to be subject to HMDA. Since 2019 was <100, 2020 and 2021 are both exempt years.

If you had said 2018 = 95 and 2019 = 103, then it's possible you could be subject to HMDA beginning 1/1/2021 IF you exceeded 100 again in 2020.

Hope that helps.

Wow! That last is a tidbit I had not been aware of either. I'd best review the reg more closely.

Thank you very much David.