DIVISION OF CONSUMER AND

COMMUNITY AFFAIRS

CA 21-17

 December 17, 2021

TO THE OFFICERS AND MANAGERS IN CHARGE OF CONSUMER AFFAIRS 

SECTIONS:

Applicability to Community Banking Organizations: This guidance applies to all institutions 

supervised by the Federal Reserve, including those with total consolidated assets of $10 billion 

or less.

SUBJECT: Revised Home Mortgage Disclosure Act Examination Procedures

The Federal Reserve has recently revised Home Mortgage Disclosure Act (HMDA)1

examination procedures. These procedures are for use in connection with HMDA data collected 

since January 1, 2018 pursuant to the Consumer Financial Protection Bureau’s (Bureau) October 

15, 2015 and August 24, 2017 amendments to Regulation C,

2 which implements HMDA, and the 

Economic Growth, Regulatory Relief, and Consumer Protection Act’s (EGRRCPA) May 24, 

2018 amendments to HMDA.

3

 The examination procedures include:

• Narrative, Examination Objectives, and Examination Procedures sections that were recently 

developed by the Task Force on Consumer Compliance of the Federal Financial Institutions 

Examination Council (FFIEC). 

• Review of Compliance Management System, Examination Conclusions and Wrap-Up, and 

Examination Checklist sections that were separately developed in consultation with the 

Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the 

Currency (OCC).

• FFIEC HMDA Examiner Transaction Testing Guidelines. Including sampling, verification, 

and resubmission procedures that were transmitted with CA 17-2, key data fields information 

1 12 U.S.C. 2801 et seq.

2 See 80 FR 66127 (October 28, 2015); 82 FR 43088 (September 13, 2017); see also 12 C.F.R. part 1003.

3 Pub. L. 115-174, 132 Stat. 1296 (2018), section 104(a) (codified at 12 U.S.C. 2803).
2

that was transmitted with CA 18-9,

4 and Federal Reserve HMDA sampling and omissions 

transaction testing procedures.

HMDA and Regulation C require certain depository institutions and for-profit nondepository institutions to collect, record, and report data about originations and purchases of 

mortgage loans as well as mortgage loan applications that do not result in originations. Section 

1094 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) 

transferred rulemaking authority for HMDA to the Bureau on July 2011; amended HMDA to 

require collection, recording, and reporting of new data points; and authorized the Bureau to 

require additional information from covered institutions.5

The Bureau’s October 2015 and August 2017 final rules modified: (1) the types of 

institutions that are subject to Regulation C;6 (2) the types of transactions that are subject to 

Regulation C;7 (3) the types of data that institutions are required to collect, record, and report 

pursuant to Regulation C;8 and (4) the corresponding processes for reporting and disclosing 

HMDA data.9

On April 16, 2020, the Bureau issued a 2020 HMDA Rule to adjust the thresholds for reporting 

data about closed-end mortgage loans, effective July 1, 2020, and the thresholds for reporting 

data about open-end lines of credit, effective January 1, 2022.10 

4 The key fields are those that the Federal Reserve, the FDIC, and the OCC have determined are most critical to the 

integrity of analyses of overall HMDA data. Although the FFIEC HMDA Examiner Transaction Testing Guidelines 

themselves do not establish key fields, they state that supervisory agencies may prioritize designated fields for 

review. 

5 Public Law 111-203, 124 Stat. 1376 (2010).

6 For background information, see the Bureau’s 2017 HMDA Institutional Coverage Chart at 

http://files.consumerfinance.gov/f/201510_cfpb_2017-hmda-institutional-coverage.pdf; and the Bureau’s 2018 

HMDA Institutional Coverage Chart at 

https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201709_cfpb_2018-hmda-institutionalcoverage.pdf. 

7 For background information, see the Bureau’s 2018 HMDA Transactional Coverage Chart at 

https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201709_cfpb_2018-hmda-transactionalcoverage.pdf. 

8 The amended regulation includes several new data points, many of which were added by the Dodd-Frank Act and 

some of which were added pursuant to the Bureau’s discretionary authority to carry out the purposes of HMDA. 

The amended regulation also reflects modification of several existing data points. For background information, see

the Bureau’s Reportable HMDA Data: A Regulatory and Reporting Overview Reference Chart for HMDA Data 

Collected in 2018 at https://files.consumerfinance.gov/f/documents/201710_cfpb_reportable-hmda-data_regulatoryand-reporting-overview-reference-chart.pdf and Reportable HMDA Data: A Regulatory and Reporting Overview 

Reference Chart for HMDA Data Collected in 2019 at 

https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/cfpb_reportable-hmda-data_regulatory-andreporting-overview-reference-chart-2019.pdf. 

9 For background information, see the Bureau’s HMDA Rule Key Dates Timeline at 

https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201709_cfpb_hmda-key-dates-timeline.pdf.

10 85 Fed. Reg. 28364 (May 12, 2020).
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 This rule establishes 

• the closed-end mortgage loan threshold at 100 loans originated in each of the two 

preceding calendar years, with an effective date of July 1, 2020; and 

• the open-end line of credit threshold at 200 loans originated in each of the two 

preceding calendar years. This new 200-loan threshold will become effective on 

January 1, 2022 (i.e., data collection would occur in 2022 with reporting in 2023). 

 The 2020 HMDA Rule also provides that institutions covered by HMDA under the 25

closed-end mortgage loan threshold as of January 1, 2020, but will now be exempt under the new 

100-loan threshold, can choose to voluntarily report their HMDA data on closed-end mortgage 

loans that was collected in 2020.

For HMDA data collected prior to January 1, 2018, Reserve Banks will continue to 

examine financial institutions pursuant to the interagency HMDA examination procedures 

transmitted with CA 09-10 and the HMDA sampling and resubmission procedures transmitted 

with CA 04-4.

11 Additionally, pursuant to the Bureau’s amendments to Regulation C, from

January 1, 2017 through December 31, 2017 banks, credit unions, and savings associations were

not subject to Regulation C if they did not originate 25 home purchase loans, including 

refinancings of home purchase loans, in each of the two preceding calendar years.12

Reserve Banks are asked to distribute this letter to the supervised institutions in their 

districts and to appropriate supervisory staff. Questions regarding this letter may be sent via the 

Board’s public website.13 

Sincerely, 

Benjamin K. Olson

Senior Associate Director

Attachment:

• Revised Home Mortgage Disclosure Act Examination Procedures

Cross-references:

• CA 21-7 “Revised A Guide to HMDA Reporting: Getting It Right!” (March 30, 2021)

11 Likewise, CA 06-3, CA 04-11, and CA 93-2 continue to apply with regard to HMDA data collected prior to 

January 1, 2018. For additional information on key HMDA dates and implementation, see the Bureau’s HMDA 

Rule Key Dates Timeline, supra note 9.

12 See the Bureau’s 2017 HMDA Institutional Coverage Chart, supra note 6.

13 See http://www.federalreserve.gov/apps/contactus/feedback.aspx. 
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• CA 18-9 “Revised Designated Home Mortgage Disclosure Act Key Data Fields” 

(December 7, 2018)

• CA 18-6 “Statement on the Implementation of the Economic Growth, Regulatory Relief, 

and Consumer Protection Act Amendments to the Home Mortgage Disclosure Act” (July 

5, 2018)

• CA 17-4 “Expectations for Supervised Institutions Regarding Amended Regulation C” 

(December 21, 2017)

• CA 17-2 “Revised Interagency Home Mortgage Disclosure Act Sampling, Verification, 

and Resubmission Procedures” (August 22, 2017)

• CA 06-3 “Extension of Provisional HMDA Data Sampling Procedures” (January 1, 2006)

• CA 93-2 “Guidance on Coverage of the Home Mortgage Disclosure Act (HMDA) to 

Certain Foreign Banking Organizations (FBOs)” (March 3, 1993)