AL 97-1
Subject:  Home Mortgage Disclosure Act Reporting of Data

TO:  Chief Executive Officers of all National Banks, Department
     and Division Heads, and all Examining Personnel

This advisory is being sent to remind national banks that civil
money penalties (CMP) may be assessed for violations of the data
collection and reporting requirements of the Home Mortgage
Disclosure Act (HMDA).

It is the policy of the Office of the Comptroller of the Currency
to consider assessing a CMP against a national bank whenever a
bank submits a delinquent or inaccurate Home Mortgage Disclosure
Act Loan Application Register.  In determining the
appropriateness of the penalty, the Comptroller will consider the
statutory factors, as provided under 12 USC 1818(I)(2)(g). 
Specifically, these factors are size of financial resources, good
faith, gravity of the violation, history of previous violations,
and other matters as justice may require.

HMDA data continues to be used by bank regulators, the public,
the media, and others as an indicator of how well reporting
institutions are meeting the mortgage finance needs of low- to
moderate-income and minority consumers.  Aggregate HMDA data from
1993-1995 show that conventional mortgage loans to Black
Americans increased 70 percent and those to Hispanics increased
48 percent.  These are laudable increases for the mortgage
industry at large.  However, the OCC continues to discover HMDA
data submitted by reporters that contain significant errors, data
that were not reported, and data submitted too late to be
aggregated and disclosed to the public in a timely manner.

To ensure the accuracy and timely reporting of HMDA data, a
bank's board and senior management need to ensure the
effectiveness of internal controls used to collect and report the
data.  There is no absolute safeguard against all errors, but
establishing adequate controls to identify errors coupled with a
periodic review and assessment of those controls is fundamental
to minimizing the potential for submission of erroneous or late
data.

Questions concerning this advisory may be directed to the
Compliance Management Department at (202) 874-4446.


                                    
Bert A. Otto
Acting Deputy Comptroller
   for Compliance Management
Date:     January 22, 1997