HMDA Reporting and Multifamily Finance

MBA's 2019 Commercial/Multifamily Policy Priorities

Reference Resources

The CFPB should amend HMDA regulations (Regulation C) to exempt business-to-business loans secured by multifamily property.

Overview: The Home Mortgage Disclosure Act (HMDA) requires mortgage lenders to collect and report information on specific data points pertaining to their lending practices. 

Under Consumer Financial Protection Bureau (CFPB) implementing rules at Regulation C, as amended in 2020 following MBA advocacy, financial institutions that originate at least 100 covered commercial mortgage loans secured by single-family or multifamily property in each of the two preceding calendar years and meet other specifications for either depository or non-depository financial institutions, are required to collect and report HMDA data.  

MBA continues to urge the CFPB to also revise Regulation C to exempt business-to-business loans secured by multifamily property

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