The CFPB recently issued a final rule increasing the asset exemption threshold under the Home Mortgage Disclosure Act (HMDA).
Banks, savings associations and credit unions are not subject to the mortgage loan data collection and reporting requirements under HMDA for a calendar year if their assets as of December 31 of the prior calendar year did not exceed an asset threshold. The asset threshold is subject to annual adjustment based on inflation. The asset threshold for calendar year 2024 HMDA data collection and reporting is $56 million. The final rule increases the asset threshold for calendar year 2025 HMDA data collection and reporting to $58 million. As a result, banks, savings associations, and credit unions with assets of $58 million or less as of December 31, 2024, are exempt from collecting and reporting HMDA data for 2025 activity.