The Office of the Comptroller of the Currency today issued a bulletin to inform banks and examiners that the loan origination threshold for reporting Home Mortgage Disclosure Act data on closed-end mortgage loans has changed due to a recent court decision. The threshold for reporting is now 25 closed-end mortgage loans originated in each of the two preceding calendar years.
Banks that originated at least 25 closed-end mortgage loans in each of the two preceding calendar years but fewer than 100 closed-end mortgage loans in either or both of the years may need to make adjustments to policies and procedures to comply with reporting obligations, the OCC said. The agency does not intend to assess penalties for failures to report closed-end mortgage loan data on reportable transactions conducted in 2022, 2021 or 2020 for affected banks that meet Regulation C’s other coverage requirements
