The NCUA recently announced that if your credit union makes residential mortgage loans and meets all four criteria outlined below, you must comply with the Consumer Financial Protection Bureau’s Regulation C, which implements the Home Mortgage Disclosure Act.
Regulation C requires you to collect HMDA data associated with mortgage loan applications processed during 2020, if:
- Your credit union’s total assets as of Dec. 31, 2019, exceeded $47 million;
- Your credit union had a home or branch office in a Metropolitan Statistical Area on Dec. 31, 2019;
- Your credit union originated at least one home purchase loan (other than temporary financing such as a construction loan) or refinanced a home purchase loan, secured by a first lien on a one-to-four-unit dwelling during 2019; and
- Your credit union originated at least 25 closed-end mortgage loans in each of the two preceding calendar years (2018 and 2019) or 500 open-end lines of credit in each of the two preceding calendar years (2018 and 2019).
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