February 3, 2023

FDIC: Update on Supervisory Approach Regarding Changes to HMDA’s Closed-End Mortgage Loan Volume Reporting Threshold

The Federal Deposit Insurance Corporation (FDIC) is issuing this Financial Institution Letter to inform supervised institutions of recent changes regarding the Home Mortgage Disclosure Act (HMDA) reporting threshold for closed-end mortgage loans and the FDIC’s supervisory approach for enforcing related requirements. For FDIC-supervised institutions that meet Regulation C’s coverage requirements, the threshold for reporting data on closed-end mortgage loans is now 25 loans in each of the two preceding calendar years. In addition, for closed-end mortgage data collected in the years 2022, 2021, or 2020, the FDIC does not intend to initiate enforcement actions or cite HMDA violations for certain failures to report such loan data, as described in detail below.

Statement of Applicability: The contents of, and material referenced in, this FIL apply to all FDIC-supervised financial institutions.


On September 23, 2022, the United States District Court for the District of Columbia (Court) issued an order vacating the CFPB 2020 HMDA Final Rule regarding the loan volume reporting threshold requirements for closed-end mortgage loans. 

This post was originally published here.