OCC updates HMDA examination procedures

Bank Regulatory Agency Rule-Making & Guidance OCC HMDA Mortgages Open-End Credit Examination

On December 17, the OCC released revised interagency HMDA examination procedures for HMDA compliance. The revised examination procedures address changes made to the effective dates for banks meeting or exceeding either the closed-end mortgage loans or the open-end lines of credit loan-volume threshold in each of the two preceding calendar years. Effective July 1, 2020, a bank that “originated at least 100 closed-end mortgage loans in each of the two preceding calendar years, or originated at least 500 open-end lines of credit in each of the two preceding calendar years meets or exceeds the loan-volume threshold.” Effective January 1, 2022, the temporary 500 open-end lines of credit provision expires, and a bank that “originated at least 100 closed-end mortgage loans in each of the two preceding calendar years, or originated at least 200 open-end lines of credit in each of the two preceding calendar years” will now meet or exceed the loan-volume threshold. The revised examination procedures also outline changes to partial exemptions for an application or covered loan. A partial exemption applies to: (i) applications for originations of, and purchases of closed-end mortgage loans when the bank originated fewer than 500 closed-end mortgage loans in each of the two preceding calendar years, and (ii) applications for originations of, and purchases of open-end lines of credit provided the bank originated fewer than 500 open-end lines of credit in each of the two preceding calendar years.

Bulletin 2021-63 rescinds OCC Bulletin 2010-8, “Compliance Policy: Revised Home Mortgage Disclosure Act Examination Procedures,” as well as OCC Bulletin 2019-19, “Home Mortgage Disclosure Act: Revised Interagency Examination Procedures.”