How many owner-occupied loans must a non-depository institution close to be subject to HMDA reporting?

The requirement for a non-depository institution to be subject to Home Mortgage Disclosure Act (HMDA) reporting hinges on the number of owner-occupied loans it originates. Specifically, a non-depository institution must close 100 owner-occupied loans in a calendar year to trigger the HMDA reporting obligations. This is part of the effort to ensure transparency and monitoring of lending practices, particularly in regard to fair lending.

The 100-loan threshold is significant because it sets a standard that allows regulators to collect data on lending patterns and trends, thereby providing protections for consumers and enabling oversight of lending institutions with respect to compliance with fair lending laws. By focusing on owner-occupied loans, the regulation emphasizes the importance of transparency in primary residences, where homeowners typically face the largest financial commitments.

Understanding this threshold is crucial for any mortgage loan officer, as it helps in identifying when their organization enters the realm of HMDA reporting requirements and aligns with broader regulatory compliance mandates.