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Blog Post
CFPB Revises HMDA and Small Creditor Asset Thresholds for 2023
Michael Christians • December 28, 2022
Rounding out the required threshold adjustments for 2023, the Consumer Financial Protection Bureau (CFPB) has published the revised asset thresholds under Regulation C's institutional coverage test and Regulation Z's definition of a small creditor.
Home Mortgage Disclosure Act (HMDA)
A creditor that meets the following institutional coverage test under Regulation C is required to report its HMDA data:
- Assets over a certain threshold as of December 31st of the preceding calendar year
- Home or branch office in a Metropolitan Statistical Area (MSA)
- Originated at least one home purchase or refinance transaction in the preceding calendar year; and
- Federally insured or regulated.
For 2023, the asset threshold has increased from $50 million to $54 million.
Small Creditor
Among other things, institutions that meet the definition of a small creditor are exempt from the following regulatory requirements:
- The pricing test component of the revised definition of a qualified mortgage; and
- Establishing an escrow account in connection with a higher priced mortgage loan secured by a first lien.
For 2023, a small creditor is an institution that:
- During the preceding calendar year, together with its affiliates originated 2,000 or fewer covered transactions secured by a first lien; and
- At the end of the preceding calendar year, together with its affiliates has total assets of less than $2.537 billion.
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5438 South Prairie View Drive
West Des Moines, IA 50266
Phone
319-325-1171
michael@mchristiansconsulting.com
Michael Christians Consulting, LLC
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