Loan impact
From the interpretation text · verifiedApplies to: Banks, savings associations and credit unions with assets of $59 million or less as of December 31, 2025 are exempt from HMDA data collection in 2026.
- Exceptions
- Exemption from 2026 collection does not affect responsibility to report data required to be collected in 2025
- Effective
- Jan 7, 2026
- Applicability confidence
- Verified: every row above is supported by the source text
Supporting quotes from the interpretation
- exceptions“An institution’s exemption from collecting data in 2026 does not affect its responsibility to report data it was required to collect in 2025.”
- guide sections“Pursuant to this final rule, comment 2(g)–2 in Regulation C, supplement I, is amended to update the exemption threshold.”
What changed
From the interpretation text · Section Supplement I to Part 1003, comment 2(g)–2| Requirement | Previously | Now |
|---|---|---|
| HMDA asset-size exemption threshold for depository institutionsRelaxed | Previously: $58 million threshold for 2025 | $59 million threshold for 2026; institutions with assets at or below $59 million as of December 31, 2025 are exempt from collecting 2026 data |
Also affected: Section comment 2(g)–2.
What to do
AWACS interpretation · not source languageWhat to review: Compliance may review whether the raised threshold, now $59 million for 2026 data collection and up from $58 million, exempts the institution from collecting 2026 data, keeping in mind that data required to be collected in 2025 must still be reported.
QC implications
- Check that any institution relying on the exemption had assets of $59 million or less as of December 31, 2025 and is a bank, savings association or credit union.
- Confirm that an institution's exemption from 2026 collection is not treated as relieving it of reporting data it was required to collect in 2025.
Source and record
Version 1 · archivedChecks passed
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Source
- Final rule; official interpretation FR Doc. 2026-00087 (official) ↗ (opens in a new tab)
- Archived copy, SHA-256 3e94d551d352…
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