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Counting loans for the new closed-end HMDA threshold

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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?

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.


Learn more about Kathleen Blanchard’s webinar New HMDA Changes

First published on 05/10/2020

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