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Exception Tracking Spreadsheet (TicklerTrax™)
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OCC Bulletin on HMDA closed-end reporting threshold change

The OCC has issued Bulletin 2023-5 to announce that the loan origination threshold for reporting HMDA data on closed-end mortgage loans was reduced to 25 closed-end loans originated in each of the two preceding calendar year.

While this is "old news" at this point, the Bulletin clarifies the OCC's intentions regarding failures to report closed-end mortgage loan data before 2023. The OCC says it "does not intend to assess penalties for failures to report closed-end mortgage loan data on reportable transactions conducted in 2022, 2021, or 2020 for affected banks that meet Regulation C’s other coverage requirements."

The Bulletin also says that OCC examinations "conducted in affected banks regarding HMDA reportable transactions from 2022, 2021, or 2020 will be diagnostic to help banks identify compliance weaknesses," and "collection and submission of 2023 HMDA data will provide affected banks with an opportunity to identify gaps in and make improvements to their HMDA compliance management systems."

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