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Collecting data if now exempt for 2020

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Question: 
Our financial institution did not originate 100 HMDA reportable closed-end loans in 2019 and therefore is no longer a required reporter for 2020. Can we stop collecting immediately?
Answer: 

No. The revised threshold does not go into effect until July 1, 2020. Your financial institution must continue to gather HMDA data until June 30, 2020 but will not be required to submit a HMDA LAR for 2020. This seems odd but we do not ordinarily see a mid-year implementation of an annual reporting requirement.

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Learn more about Kathleen Blanchard’s webinar New HMDA Changes

First published on 05/17/2020

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