The Consumer Financial Protection Bureau (CFPB) is raising the exemption threshold determining which financial institutions are required to maintain, report and publicly disclose loan-level information about mortgages under the Home Mortgage Disclosure Act (HMDA).
According to a CFPB rule posted this week in the Federal Register, banks, savings associations and credit unions with assets of $59 million or less as of Dec. 31, 2025, are exempt from collecting that loan-level data in 2026.
In 2025, the exemption level was set at $58 million.
Additionally, the CFPB upped the threshold at which certain insured depository institutions and credit unions are required to establish an escrow account for a higher-priced mortgage loan (HPML), which is a loan that exceeds a specified amount over the benchmark average prime offer rates calculated weekly by the CFPB.
Under the revised rule, the exemption threshold for creditors and their affiliates that regularly extend covered transactions secured by first liens is now $2.785 billion. The exemption threshold for certain insured depository institutions and insured credit unions with assets of $10 billion or less is now $12.485 billion.
The adjustments are based on year-over-year changes to the average of the consumer price index for urban wage earners and clerical workers for the 12-month period ending in November, rounded to the nearest $1 million.
The CFPB noted that it determined the changes did not require a public notice or commentary period, as the amendments were “technical and non-discretionary.”
The Home Mortgage Disclosure Act was enacted by Congress in 1975. The Dodd-Frank Act, enacted in 2010, transferred HMDA authority to the CFPB, which began operation in 2011.
