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Counting loans for the new closed-end HMDA threshold

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Question: 
Should the financial institution count all transactions on its HMDA LAR for the 2 preceding calendar years to determine if it is no longer required to report for HMDA?
Answer: 

No. Count only actually originations, those with action code 1, on the HMDA LAR. Treat each calendar year separately. The threshold of 100 closed-end loans would need to be met for 2018 and for 2019 for the financial institution to be a required reporter in 2020.

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Learn more about Kathleen Blanchard’s webinar New HMDA Changes

First published on 05/10/2020

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