New Analysis Supports Raising HMDA Reporting Threshold for Closed-End Mortgages

In a comment letter to the Consumer Financial Protection Bureau this week, ABA urged the bureau to consider raising the coverage thresholds for collecting and reporting data about closed-end mortgage loans to 250.

ABA had recommended an increase to 200 in a June comment letter; however, new analysis of the 2018 HMDA data—provided to ABA by Asurity Technologies—demonstrates that the threshold “could be raised to 250 without causing meaningful loss of data,” the association wrote. The data showed that more than doubling the threshold size would exclude an additional 222,538 transactions, while reducing reported originations by only 4.25%.

“Considering the costs of HMDA compliance . . . we urge the bureau to revisit these calculations and consider this higher threshold,” ABA said.