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Statement on Supervisory and Enforcement Practices Regarding Quarterly Reporting Under the Home Mortgage Disclosure Act

The Bureau recognizes that mortgage lenders play a vital role in ensuring that consumers have access to credit. This access is especially critical in responding to the dramatic effects on the finances of consumers as a result of the coronavirus crisis. The Bureau is therefore issuing this policy statement in order to provide lenders with flexibility and reduce administrative burden, allowing them to focus their time and attention on making sure consumers continue to have such access.

Effective January 1, 2020, under the Home Mortgage Disclosure Act (HMDA), 12 U.S.C. 2801 through 2810, and Regulation C, 12 CFR 1003.5(a)(1)(ii), financial institutions that report for the preceding calendar year at least 60,000 covered loans and applications (excluding purchased loans) must report their HMDA data quarterly (except for the fourth quarter) in addition to annually. The first quarterly submissions in 2020 are due by May 30.

As of March 26, 2020, and until further notice, the Bureau does not intend to cite in an examination or initiate an enforcement action against any institution for failure to report its HMDA data quarterly. At a later date, the Bureau will provide information as to how and when it expects institutions under its jurisdiction to resume quarterly HMDA data submissions. Entities should continue collecting and recording HMDA data in anticipation of making annual data submissions.

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