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