Whether a financial institution is subject to HMDA depends on meeting certain criteria. For instance, an institution must have, at of the end of the prior calendar year, exceeded the asset-size threshold (currently $59 million); had a home office or branch located in a Metropolitan Statistical Area (MSA); originated at least one home purchase or refinancing of a home purchase loan secured by a 1-4 family dwelling; and met certain origination volume tests in each of the prior two years (25 covered closed-end / 200 covered open-end).
The above, however, only determines whether an institution is subject to HMDA. If it is, then the institution must determine whether it is a large filer or a small filer.
A small filer is an institution that:
- Originated 25-499 closed-end loans in each of the prior two years
- Originated 200-499 open-end lines in each of the prior two years
Small filers may report limited data for loans and/or lines.
David explains more in the video.
Published 2026/02/23
