DIVISION OF CONSUMER AND

COMMUNITY AFFAIRS

CA 23-2

April 13, 2023

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 “A Guide to HMDA Reporting: Getting It Right!”

The Task Force on Consumer Compliance of the Federal Financial Institutions 

Examination Council recently developed a revised version of “A Guide to HMDA Reporting: 

Getting It Right!” (Guide). The updated Guide is intended to assist financial institutions in 

complying with the Home Mortgage Disclosure Act (HMDA)1 as implemented by the Consumer 

Financial Protection Bureau’s (CFPB) Regulation C.2 This Guide applies to HMDA data that 

financial institutions are required to collect beginning on January 1, 2023 and must submit by 

March 1, 2024. The Guide provides helpful background information and an easy-to-use summary 

of certain key requirements, including those relating to institutional coverage, transactional 

coverage, and data collection, reporting, and disclosure requirements.

This edition of the Guide incorporates the amendments made to HMDA by the DoddFrank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act)3 and the Economic 

Growth, Regulatory Relief, and Consumer Protection Act (the 2018 Act).4 The Dodd-Frank Act 

amended HMDA, transferred rulewriting authority to the CFPB and expanded the scope of 

information that must be collected, reported, and disclosed under HMDA, among other changes. 

In October 2015, the CFPB issued the 2015 HMDA Rule implementing the Dodd-Frank Act 

amendments to Regulation C.5 The 2015 HMDA Rule modified the types of institutions and 

transactions subject to Regulation C, the types of data that institutions are required to collect, and 

the processes for reporting and disclosing the required data.6

1 12 U.S.C 2801 et seq. 2 12 C.F.R. Part 1003.

3 Public Law No. 111-203, 124 Stat. 1376, 2097-2101 (2010). 4 Public Law No. 115-174, 132 Stat. 1296 (2018). 5 80 FR 66128 (October 28, 2015) (2015 HMDA Rule).

6 2015 HMDA Rule, 80 FR 66128-29. 
2

On August 24, 2017, the CFPB issued a 2017 HMDA Rule to further amend Regulation 

C to make technical corrections and clarify and amend certain requirements adopted by the 2015 

HMDA Rule.7

The 2018 Act amended HMDA by adding partial exemptions from HMDA’s 

requirements for certain transactions made by certain insured depository institutions and insured 

credit unions. On August 31, 2018, the CFPB issued a 2018 HMDA Rule to implement and 

clarify changes made by the 2018 Act.8

On October 10, 2019, the CFPB issued a 2019 HMDA Rule to extend the temporary 

threshold for reporting data about open end lines of credit and implement and further clarify the 

partial exemptions created by the 2018 Act.9

On April 16, 2020, the CFPB 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

On September 23, 2022, the United States District Court for the District of Columbia 

issued an order vacating and remanding the loan-volume reporting threshold for closed-end 

mortgage loans under the 2020 HMDA Rule.11 As a result, the threshold for reporting data about 

closed-end mortgage loans is 25, the threshold set by the 2015 HMDA Rule. On December 12, 

2022, the CFPB issued a technical amendment to reflect the order by adjusting the closed-end 

reporting threshold numbers in Regulation C accordingly.12

Reserve Banks are asked to distribute this letter to the Federal Reserve-supervised 

institutions in their districts, as well as to their supervisory and examination staff. If supervised 

financial institutions have questions about the guidance set forth in this letter, they are 

encouraged to contact the responsible Reserve Bank. In addition, questions may be sent via the 

Board’s public website.13

Sincerely,

Eric Belsky

Director

7 82 FR 43088 (September 13, 2017) (2017 HMDA Rule).

8 83 FR 45325 (Sept. 7, 2018) (2018 HMDA Rule). 9 84 FR 57946 (Oct. 29, 2019) (2019 HMDA Rule). 10 85 FR 28364 (May 12, 2020) (2020 HMDA Rule). 11 Nat’l Cmty. Reinvestment Coal., et al. v. Consumer Fin. Prot. Bureau, No. 20–cv–2074, 2022 WL 4447293 

(D.D.C. Sept. 23, 2022). 

12 87 FR 77980 (Dec. 21, 2022). 13 See http://www.federalreserve.gov/apps/contactus/feedback.aspx.
3

Attachment: 

• Revised “A Guide to HMDA Reporting: Getting It Right!”

Cross References: 

• CA 23-1 “Changes to Home Mortgage Disclosure Act Loan Volume Reporting 

Threshold for Closed-end Mortgage Loans” (January 31, 2023)

• CA 21-17 “Revised Home Mortgage Disclosure Act Examination Procedures” 

(December 17, 2021) 

• CA 18-9 “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)