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Checking your HMDA reporting status

Question: 
What time periods are reviewed to determine if a financial institution is a HMDA reporter for the coming year?
Answer: 

As of each January 1st, look at the total HMDA reportable originated closed-end loans and open-end lines of credit from the prior 2 calendar years. Of course, you want to monitor originations throughout the year, but as of January 1, look at totals through the full prior 2 calendar years. For example, if the closed end threshold of 25 originated HMDA reportable loans was met in 2018 and 2019, and all other requirements to be a HMDA reporter have been met, the financial institution will be a HMDA closed end reporter as of January 1, 2020.
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Learn more about Kathleen Blanchard’s webinar HMDA – Thresholds, Exemptions, Temporary, Partial – How It All Works

First published on 10/27/2019

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