Question of the Week
Friday, February 16, 2018 8:10 AM

Question:  With the filing deadline of March 1 coming up, what factors would require my credit union to file Home Mortgage Disclosure Act information for this past year?

Answer:  A financial institution is required to file in for reporting year 2017 if it:

  • Has total assets of $44 million as of the close of business on December 31, 2016,
  • Has an office in a Metropolitan Statistical Area (MSA), as defined by the Office of Management and Budget,
  • Originated at least one home purchase loan or refinancing of a home purchase loan secured by a first lien on a one-to-four family dwelling,
  • Was federally insured or regulated, or the institution originated at least one mortgage loan that was insured, guaranteed, or supplemented by a federal agency, or the institution originated at least one mortgage loan that was intended for sale to Fannie Mae or Freddie Mac, AND
  • The financial institution originated at least 25 home purchase loans, including refinancings of home purchase loans in each of the two preceding calendar years (that is, at least 25 in 2015 and at least 25 in 2016).

Be aware that these requirements are for 2017 reporting only, and that they will change in 2018 to include HELOCs data if the financial institution originated 100 HELOCs in 2016 and 2017.  The total asset threshold will also adjust to $45 million.