DATE: December 17, 1997
NO. 97-RA-14
TO: Credit
Unions Subject To Home Mortgage Disclosure Act (HMDA)
Reporting Requirements
SUBJECT: Changes
to the HMDA Reporting Requirements
The Federal Financial Institutions Examination
Council (FFIEC) has issued a letter to credit unions subject to
HMDA reporting requirements highlighting the previously announced
changes in rules or reporting requirements for 1997. Attached
is the letter discussing the changes that will impact the upcoming
reporting cycle.
The letter also serves as a supplement to the
1996 Guide to HMDA Reporting: Getting It Right!, which
should be utilized for guidance on requirements for 1997 data
collection and reporting. To obtain copies of the Guide to
HMDA Reporting: Getting It Right!, you may contact FRS Publications
at (202) 452-3245.
Sincerely,
/S/
Norman E. D'Amours
Chairman
Attachment
Federal Financial Institutions
Examination Council
2100 Pennsylvania Avenue, NW, Suite
200 Washington, DC 20037 (202) 634-6526 FAX (202) 634-6556
November 19, 1997
TO ALL LENDING INSTITUTIONS SUBJECT TO HOME
MORTGAGE DISCLOSURE ACT REPORTING REQUIREMENTS
As calendar year 1997 draws to a close, your
institution will be taking steps to complete Home Mortgage Disclosure
Act (HMDA) data compilation for the fourth quarter and to double-check
HMDA-LAR entries for accuracy and completeness. The 1997 report
must be received by your supervisory agency, at the address listed
in Appendix G of the Guide to HMDA Reporting: Getting It Right!,
no later than March 2, 1998.
This letter is intended to serve as a reminder
regarding previously announced changes in rules or reporting requirements
for 1997. These relate to:
In addition, large institutions subject to
the Community Reinvestment Act (CRA) are reminded of the requirement
to provide property location for all HMDA-LAR entries, and not
just for MSAs in which they have offices. You may rely on the
1996 Guide to HMDA Reporting, as supplemented by this letter,
for guidance on requirements for 1997 data collection and reporting.
Revisions to Regulation C
The Federal
Reserve Board adopted changes to Regulation C in May 1997, following
statutory amendments enacted in 1996 (62 FR 28620, May 27, 1997;
correction, 62 FR 33339, June 19, 1997). First, the asset-size
exemption for depository institutions has been increased from
$10 million to $28 million. Accordingly, depository institutions
with assets of $28 million or less as of December 31, 1996, are
exempt from 1997 data collection and reporting.
(These institutions, if covered in 1996, were
still required to report their 1996 data by March 1, 1997.) The
asset threshold will be adjusted each year based on changes in
the Consumer Price Index; the Federal Reserve Board will announce
the threshold applicable to 1998 data collection in December 1997.
The increase in the asset threshold does not apply to nondepository
institutions subject to HMDA; the threshold for nondepository
institutions remains at $10 million as in previous years.
The second change included in the amendments
to Regulation C is a new option for making disclosures available
to the public. Previously, institutions were required to make
disclosure statements available at their home offices, and also
in at least one branch office in each additional MSA where they
had an office. Under the amendment, as an alternative to having
disclosure statements available in branch offices, institutions
may post a notice that disclosure statements are available upon
request, and then send a copy of the statement within 15 days
of receiving a written request.
The third change was to the Transmittal Sheet
that accompanies the Loan Application Register; a blank has been
added for the institution's fax number, and the requirement to
enter the name and address of the institution's supervisory agency
has been dropped.
For details on any of these changes to Regulation
C, please refer to the Federal Register notice of the amendments
referred to above.
Changes in Metropolitan Statistical Areas
The following changes in MSAs were announced
by the Office of Management and Budget to take effect for 1997
HMDA data collection:
Add these entries to the list contained in
the 1996 HMDA Guide.
Property Location Reporting for Large Institutions
Subject to CRA
Large institutions subject to the CRA are
reminded that they must report the property location for all applications
and loans on their HMDA-LAR. This requirement applies whether
the property is located in an MSA where the institution has a
home or branch office, in some other MSA, or in a non-MSA area.
The requirement applies to banks and savings associations that
had total assets of $250 million or more (and to banks and savings
associations that are subsidiaries of holding companies whose
total banking and thrift assets were $1 billion or more) as of
December 31 for each of the preceding two years.
Examples: For a loan on property in a rural,
non-MSA area that does not have census tracts, the institution
would report using NA for the MSA, the two-digit state code and
three-digit county code, and, in the census tract field, the BNA
number or NA. For a loan on property in an MSA (whether or not
the institution has offices there), the institution would report
the MSA, state, and county codes, and the census tract number.
If you have any questions regarding any of
the points discussed above, or on other HMDA matters, please call
your supervisory agency.