The HMDA Filing Instructions Guide (FIG) has been updated for data collected in 2022. As this guide is updated an an annual basis for the new year, there appears to be minimal changes in the newest version of the Guide.

On June 14, 2021, the CFPB issued a report that reviews differences in lending patterns for lenders below and above the 100-loan closed-end threshold set by the 2020 Home Mortgage Disclosure Act rule. The CFPB also issued a blog post that explains the data source and analytical approach, as well as key findings from their report. Even though the information presented in the report covers all 2019 HMDA reporters with closed-end origination volume below 1,000, the CFPB explains that their report highlights the contrasts between the reporters whose origination volume was below 100 and those whose origination volume was over 100, as 100 corresponds to the closed-end reporting threshold set by the 2020 HMDA Rule.

On 3/31/2021, the FDIC announced that the Federal Financial Institutions Examination Council (FFIEC) had issued the 2021 edition of A Guide to HMDA Reporting: Getting It Right! for Home Mortgage Disclosure Act (HMDA)-related data collected in 2021 and reported in 2022. This longstanding compliance resource has regularly been used by financial institutions as a “go-to” HMDA resource as it can help financial institutions better understand HMDA requirements, including the data collection and reporting provisions.

On December 22, 2020, the CFPB adjusted the HMDA exemption threshold from $47 million to $48 million. The adjustment is based on the 1.3 percent increase in the average of the CPI-W for the 12-month period ending in November 2020 (down from 2.6 in 2018 and 1.6 in 2019). Therefore, banks, savings associations, and credit unions with assets of $48 million or less as of Dec. 31, 2020, are exempt from collecting data in 2021.

In August, September, October, and November of 2020, the CFPB updated their Filing instructions guide for HMDA data collected in 2021. Updates to this guide are made annually, and there have been several different updates and versions to the FIG so far. HMDA filers will need to be sure to monitor the 2021 FIG to ensure they are using the current version of the guide.

On 10/15/2020, the CFPB released a new HMDA reference chart titled “Reportable HMDA Data: A Regulatory and Reporting Overview Reference Chart for HMDA Data Collected in 2021.” In the chart, the CFPB explains that the chart is intended to be used as a reference for data points that must be collected, recorded, and reported under HMDA rules. The chart includes applicable regulation and commentary sections as well as parts of the Filing Instruction Guide. In addition, the chart helps to explain when to report not applicable or exempt, including the codes used for reporting not applicable or exempt.

On 8/27/2020, the CFPB released a second article to provide further observations found when analysing the 2019 HMDA data. In their release, the CFPB explains that this article is on cross-sectional analyses with a goal to explore various patterns and relationships between different data fields and to provide some initial observations.

On July 28, 2020, the CFPB released two new FAQs relating to the Home Mortgage disclosure Act (HMDA). This update is the second update to the CFPB’s HMDA FAQs in 2020, and those institutions still subject to HMDA reporting should review these new FAQs for compliance in your organization.