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Category: Data point

A Brief Note on General Lending Patterns of Small to Medium Size Closed-end HMDA Reporters

The 2015 HMDA Rule required that financial institutions that originated no fewer than 25 closed-end mortgage loans in each of the two preceding years and meet other reporting criteria such as asset and locational tests report their closed-end mortgage activities under HMDA. This “25-loan” closed-end reporting threshold applied to HMDA reporting activity years of 2018 and 2019. In May 2020, the CFPB raised this 25-loan threshold to 100-loans in the 2020 HMDA Rule. This Data Point article uses the 2019 HMDA data, for which the 25-loan threshold still applied, to examine certain loan and borrower characteristics and general lending patterns of small to medium sized closed-end mortgage reporters of different origination volumes.

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