On January 7, 2026, the CFPB issued a final rule that adjusted the HMDA exemption threshold from $58 million to $59 million. The adjustment is based on the 2.5 percent increase in the average of the CPI-W for the 12-month period ending in November 2025. Therefore, banks, savings associations, and credit unions with assets of $59 million or less as of Dec. 31, 2025, are exempt from collecting data in 2026.

The final rule can be found here.

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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