CFPB Adjusts HMDA Asset Exemption Threshold

The CFPB has raised the HMDA asset-size exemption threshold to $59 million for 2026 HMDA data collection and reporting. Banks, savings associations, and credit unions at or below that level (measured 12/31/2025) will be exempt from 2026 HMDA data collection and reporting.​

New 2026 threshold

• For calendar year 2026 HMDA data collection and reporting, the asset-size exemption threshold is $59 million.​

• An institution with assets of $59 million or less as of December 31, 2025, is exempt from collecting and reporting HMDA data for 2026 activity.​

Recent thresholds for context

• The threshold for 2025 HMDA data collection and reporting is $58 million; institutions at or below $58 million as of December 31, 2024, are exempt for 2025.​

• The threshold for 2024 HMDA data collection and reporting is $56 million; institutions at or below $56 million as of December 31, 2023, are exempt for 2024.​

How the adjustment works

• Regulation C requires the CFPB to annually adjust the HMDA asset-size exemption using changes in the CPI-W, so the threshold typically increases over time with inflation.​

• These adjustments are implemented via final rules amending Regulation C and apply prospectively to the next calendar year’s HMDA data collection and reporting obligations.​