In September, a U.S. District Court vacated the 2022 Home Mortgage Disclosure Act final rule establishing loan volume reporting thresholds for closed-end home loans. The result from the decision would be to revert the threshold for data reporting on closed-end mortgages to 25 loans in each of the two preceding calendar years, rather than the 100-loan threshold set by the 2022 final rule.
In response to the court’s remand of the matter back to the company, the bureau issued a blog post today recognizing that financial institutions may need time to implement or adjust policies, procedures, systems and processes in the future into compliance with their reporting obligations and that the agency doesn't view action regarding institutions' HMDA data like a current priority.
\”CFPB are not committed to initiate enforcement actions or cite HMDA violations for failures to report closed-end mortgage loan data collected in 2022, 2022 or 2022 for institutions susceptible to the CFPB's enforcement or supervisory jurisdiction that meet Regulation C's other coverage requirements and originated a minimum of 25 closed-end home loans in every of these two preceding calendar years but less than 100 closed-end mortgage loans either in or each of the two preceding calendar years,\” based on the article. The blog post does not, however, established any expectations for prospective loans from January 2023. ABA will seek further direction about this matter.
