Banks Under $59M Dodge Data Duty: CFPB Eases Reporting Load
Published Date: 1/7/2026
Rule
Summary
Starting in 2026, banks, savings associations, and credit unions with $59 million or less in assets won’t have to collect mortgage data, up from $58 million last year. This change follows a 2.5% rise in the cost of living and helps smaller lenders skip some paperwork. If your institution’s assets are at or below $59 million as of December 31, 2025, you’re off the hook for 2026 data collection!
Analyzed Economic Effects
2 provisions identified: 1 benefits, 1 costs, 0 mixed.
Small Lenders Exempt if Assets ≤ $59M
If you run a bank, savings association, or credit union with $59 million or less in assets as of December 31, 2025, you do not have to collect HMDA mortgage data for 2026. The threshold was raised from $58 million to $59 million based on a 2.5% CPI-W increase for the 12 months ending November 2025, and the rule is effective January 7, 2026.
2026 Exemption Doesn’t Relieve 2025 Reporting
If your institution is exempt from collecting data in 2026 because it had $59 million or less in assets on December 31, 2025, that exemption does not change your responsibility to report any data you were required to collect in 2025. Institutions must still report data they collected in 2025 even if they are exempt from 2026 collection.
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Key Dates
Department and Agencies
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