CFPB increases 2019 asset-size thresholds for HMDA reporting, Regulation Z small-creditor status

ALEXANDRIA, VA (January 24, 2019) — The Consumer Financial Protection Bureau announced increases to the maximum asset-size of credit unions exempt from collecting Home Mortgage Disclosure Act (Regulation C) data in 2019. It also raised the cap under which credit unions can be considered small creditors for certain escrow and qualified mortgage requirements under the Truth in Lending Act (Regulation Z). The December 31, 2018, issuances reflect annual adjustments required by HMDA and Regulation Z, respectively.

Credit unions with assets of $46 million or less as of December 31, 2018, are exempt from collecting 2019 HMDA data.

Review the Updated HMDA Data Thresholds

Regulation Z now provides exemptions to small creditors with assets less than $2.167 billion from maintaining mortgage escrow accounts if they comply with some requirements. Similar sized credit unions can also originate qualified mortgages without the need to comply with some Regulation Z requirements, so long as they fulfill specified conditions.

Review the New Regulation Z Exemptions

You can learn more about the Home Mortgage Disclosure Act by accessing the NCUA’s Fair Lending Compliance Resources webpage, and the Truth in Lending Act’s mortgage provisions at the Dodd-Frank Mortgage Lending Resources.

About National Credit Union Administration (NCUA)

The NCUA is the independent federal agency created by the U.S. Congress to regulate, charter and supervise federal credit unions. With the backing of the full faith and credit of the United States, the NCUA operates and manages the National Credit Union Share Insurance Fund, insuring the deposits of more than 135 million account holders in all federal credit unions and the overwhelming majority of state-chartered credit unions. The NCUA also protects consumers and educates the public on consumer protection and financial literacy issues.


Ben Hardaway


Joe Adamoli

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