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Financial Services Law Insights and Observations

FFIEC releases 2023 HMDA reporting guide

Bank Regulatory Federal Issues OCC FFIEC HMDA Mortgages Regulation C

On April 13, the OCC issued Bulletin 2023-10 announcing the Federal Financial Institutions Examinations Council’s issuance of the 2023 edition of the revised “A Guide to HMDA Reporting: Getting It Right!” The guide focuses on HMDA data submissions due March 1, 2024, and includes requirements and instructions for reporting and disclosing data for institutions and transactions covered by Regulation C. The guide also reflects a technical amendment to the 2020 HMDA Rule to adjust the loan volume thresholds (which took effect January 1) for reporting HMDA data on closed-end mortgage loans. As previously covered by InfoBytes, the CFPB issued the technical amendment last December to establish that the threshold for reporting data about closed-end mortgage loans is 25 mortgage loans in each of the two preceding calendar years, the threshold established by the 2015 HMDA Rule.