NCUA announces deadline for HMDA submissions

Credit unions required to file information are those located in metropolitan areas that engage in certain types and volume of residential mortgage lending and have assets exceeding $47 million as of Dec. 31, 2019. Reports are for mortgage loan applications received during 2020.

“Please note, the closed-end mortgage loan threshold increased from 25 to 100 effective July 1, 2020,” the letter stated. “Credit unions that originated fewer than 100 covered closed-end mortgage loans in 2018 or 2019 are not required to report any closed-end mortgage loan information for 2020.”

Reports must be submitted to the Consumer Financial Protection Bureau (CFPB) through the live HMDA platform. Submissions through other methods will not be accepted. Content should include the credit union’s loan/application register (LAR) data, review edits, and the certification the data is accurate and complete.

Data collected should be submitted in a pipe delimited text file. Tools are available to help format certain data in the required file type. The Federal Financial Institutions Examination Council also offers a LAR formatting tool that may be helpful for credit unions with small volumes of reported loans that do not use vendor or other software to prepare their HMDA data for submission.

Credit unions are also required to address all edits prior to submission. According to the letter, edit reports will not be emailed to credit unions in a PDF format; instead, they can be viewed in and downloaded from the HMDA platform. Responses to the edit reports should be made through the platform and cannot be faxed or email to the CFPB.

“NCUA expects every credit union required to report 2020 HMDA data to submit its file to the CFPB by the March 1, 2021, deadline,” the letter stated. “Credit unions appearing on a delinquent filers list could become subject to civil money penalty assessments.”