The CFPB recently issued a chart entitled Reportable HMDA Data: A Regulatory and Reporting Overview Reference Chart for HMDA Data Collected in 2023.

The chart was updated from the 2022 version to reflect the 2022 court decision in NCRC v. CFPB [Link: https://www.consumerfinancemonitor.com/2022/10/03/federal-dc-court-overturns-closed-end-loan-hmda-reporting-threshold/] invalidating the part of an April 2020 final Home Mortgage Disclosure Act (HMDA) rule issued by the CFPB that increased the HMDA reporting threshold for closed-end mortgage loans from 25 covered loans originated in each of the prior two years to 100 covered loans originated in each of the prior two years.  As previously reported, the CFPB then issued a technical rule reinstating the 25 closed-end loan threshold for the 2023 reporting year, with the result being that institutions that originated at least 25 covered closed-end mortgage loans in both 2021 and 2022 are subject to HMDA requirements for closed-end loans for calendar year 2023.

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