A GUIDE TO HMDA Reporting - FFIEC Home Page
EDITION EFFECTIVE JANUARY 1, 2013(For HMDA Submissions due March 1, 2014)A GUIDE TOHMDAReportingGetting It Right!Federal Financial InstitutionsExamination CouncilLOAN/APPLICATION REGISTERPageName of Reporting InstitutionofCity, State, ZIPAll columns (except Reasons for Denial) must be completed for each entry. See the instruApplication orLoan InformationApplication orLoan NumberDateApplicationReceived(mm/dd/ccyy)Example of Loan Originated Following PreapprovalL B - 6 8 7 4 3 9Example of Preapproval Request Denied01/15/20125 6 7 8 9 0 4 3 2 1 1 2 3 4 0 9 8 7 6 506/01/2012Example of Application Denied5 6 7 8 9 0 4 3 2 1 1 2 3 4 0 9 8 7 6 503/20/2012
A GUIDE TOHMDAReportingGetting It Right!Edition effective January 1, 2013 (for HMDA submissions dueMarch 1, 2014 or later)This edition of the Guide is the comprehensive edition for use with 2013calendar year data (due March 1, 2014). Appendices include the ConsumerFinancial Protection Bureau’s Regulation C (Home Mortgage Disclosure); theInstructions for Completion of the HMDA Loan/Application Register (LAR); thecommentary to Regulation C; the Home Mortgage Disclosure Act; state andcounty codes, together with metropolitan statistical area (MSA) and metropolitandivision (MD) numbers; contact information for the federal supervisory agencies;and the HMDA poster.April 2013
ContentsForewordivIntroductionPurposes of HMDA1Data Collection, Reporting, and Disclosure in a Nutshell1Management's Responsibilities2Who Must ReportCoverage Criteria3Definition of a “Branch Office”5Mergers and Acquisitions5Exemptions Based on State Law6Brokered or Correspondent Loans: Who Reports?6Data Reporting in GeneralThe Loan/Application Register (LAR)7Transactions to be Reported8Information to be Reported about Each Transaction8Transactions Not to be Reported9Completing the LAR Step by StepiiCaveat10Application or Loan Information10Action Taken12Property Location13Applicant Information15Sale of the Loan16Reasons for Denial16Loan Price and Lien Status16Sources of Geographic Information (Geocoding Tools)18Census Tract Street Address Lookup Resources18Census Tract Map Resources18
Submitting the LARReview and Contact Information21Checklist for Person Completing the LAR22Checklist for the Reviewing Officer23Editing the Data24Transmitting the Data24Resubmitting the Data24Disclosing the DataDisclosure of a Modified LAR26Disclosure Statements Prepared by the FFIEC26Aggregate Tables Prepared by the FFIEC26Glossary27AppendicesA— Form and Instructions for Completion of HMDA Loan/ApplicationRegisterA-1B— Form and Instructions for Data Collection on Ethnicity, Race, and SexB-1C— Regulation CC-1D— Commentary to Regulation CD-1E— The Home Mortgage Disclosure ActE-1F— State and County Codes and MSA/MD NumbersF-1G— Federal HMDA Reporting AgenciesG-1H— HMDA PosterH-1iii
ForewordA Guide to HMDA Reporting: GettingIt Right! will assist you in complying withthe Home Mortgage Disclosure Act asimplemented by The Consumer Finan cial Protection Bureau’s Regulation C, 12C.F.R. part 1003 (Regulation C). The Guidewas written to address the needs of finan cial institution managers and employeesresponsible for HMDA compliance.The Guide was developed by the memberagencies of the Federal Financial Institu tions Examination Council (FFIEC)—theConsumer Financial Protection Bureau(CFPB), the Office of the Comptroller ofthe Currency (OCC), the Federal DepositInsurance Corporation (FDIC), the Boardof Governors of the Federal Reserve Sys tem (Board), and the National Credit UnionAdministration (NCUA)—and the Depart ment of Housing and Urban Development(HUD).This edition of the Guide reflects severalchanges resulting from the Dodd-FrankWall Street Reform and ConsumerProtection Act (the Dodd-Frank Act). TheDodd-Frank Act transferred rulemakingauthority under HMDA from the Board tothe CFPB. In addition, the Dodd-FrankAct granted the CFPB supervisory andenforcement authority for entities underits jurisdiction. The Act also abolished theOffice of Thrift Supervision. In December2011, the CFPB restated the Board’simplementing regulation, Regulation C,to 12 C.F.R. 1003 (76 Fed. Reg. 78465(December 19, 2011)). The Guide hasbeen updated to reflect these changes.The Introduction reviews HMDA’s pur poses and data collection, reporting, anddisclosure requirements. It also summa rizes management’s responsibilities. Theremaining parts of the Guide describe inmore detail:what information a covered institutionmust collect,ivhow the information should bereported on the HMDA loan/applicationregister, andhow the data will be disclosed to thepublic by the institution and the FFIEC.The FFIEC produces a public disclosurestatement for every covered institutionand for every metropolitan statistical area(MSA) and metropolitan division (MD). Thedisclosures and other HMDA data areavailable from the FFIEC, by accessingthe FFIEC Internet site, www.ffiec.gov/hmda, or by sending an e-mail toHMDAHELP@frb.gov.This Guide is a general statement of therequirements of HMDA and RegulationC, not a verbatim restatement of the law.To comply fully with HMDA, you must befamiliar withRegulation C (reproduced inAppendix C to this Guide), including itsAppendices A and B (reproduced inAppendices A and B to this Guide),the Commentary to Regulation C(reproduced in Appendix D to thisGuide), andinformal guidance the CFPB mayissue from time to time on the web siteof the FFIEC.The Guide merely supplements, and doesnot substitute for, those sources. For fur ther information about compliance, con tact your federal HMDA Reporting agency(see Appendix G to this Guide).The FFIEC welcomes suggestions forchanges or additions that might make thisGuide more helpful. Write toFFIEC, 3501 Fairfax Drive,Room B-7081a,Arlington, VA 22226.Or send e-mail to HMDAHELP@frb.gov.
IntroductionPurposes of HMDAThe Home Mortgage Disclosure Actof 1975, as amended, requires manydepository and nondepository lenders tocollect and publicly disclose informationabout housing-related loans andapplications for such loans, includingseveral applicant/borrower characteristics.HMDA is implemented by the ConsumerFinancial Protection Bureau’s RegulationC (12 C.F.R. Part 1003), which includescommentary (12 C.F.R. Part 1003 Supp. I).The housing-loan data that lenders mustdisclose under HMDA:show whether financial institutionsare serving the housing needs of theircommunities;assist public officials in distributingpublic-sector investment so as toattract private investment to areaswhere it is needed; andassist in identifying possible discrimina tory leanding patterns and enforcingantidiscrimination statutes.HMDA does not prohibit any lendingactivity, nor is it intended to encourageunsound lending practices or the alloca tion of credit.Data Collection, Reporting,and Disclosure in a NutshellAs implemented by the Bureau's Regula tion C, HMDA requires covered depositoryand nondepository institutions to collectand publicly disclose information aboutapplications for, originations of, and pur chases of home purchase loans, homeimprovement loans, and refinancings.Whether an institution is covered dependsgenerally on its asset size, its location, andwhether it is in the business of residentialmortgage lending. The regulation’s cover age criteria are illustrated in diagrams inthe next chapter.Who Must Report.There are three categories of loans thatmust be reported: home purchase, homeimprovement, and refinancing. Each hasa specific definition, which may vary fromyour institution’s use of the term. You willfind the definitions in the chapter DataReporting in General. There you willalso find a list of types of transactionsthat are not reportable under HMDA.Every loan application, origination, andpurchase that falls into one or more of thethree categories must be reported. Withsome exceptions, for each transactionthe lender reports data about:the loan, such as its type and amount;the property, such as its location andtype;the disposition of the application, suchas whether it was denied orresulted in an origination; andthe applicant (namely, ethnicity, race,sex, and income).That information must be recorded ona form known as the HMDA loan/appli cation register (variously known as theHMDA-LAR, the LAR, or the register).A summary of the instructions for com pleting the LAR appears in the chapterCompleting the LAR Step by Step.Additional information essential toreporting property location appears in thechapter Sources of GeographicInformation (Geocoding Tools).1
IntroductionAn institution must transmit its LAR tothe data processor (FFIEC), ordinarily inelectronic form, and preferably by usingthe Submission via Web option or Inter net e-mail with an encrypted file (HRIDAgency Year.ENC) attachment. Instruc tions concerning transmittal can be foundin Submitting the LAR. Every reportinginstitution must also disclose its LAR to thepublic after deleting information that mightcompromise consumer privacy. See Dis closing the Data.The FFIEC, on behalf of the agencies, cre ates a series of tables from each institu tion’s data. Every institution must make itstables available to the public. In addition,the FFIEC will prepare and release tablesthat aggregate all reporting institutions’data by metropolitan statistical area ormetropolitan division. Those disclosuresare discussed in more detail in Disclosingthe Data.Management'sResponsibilitiesIf your institution is required to comply withHMDA, management must ensure that:Procedures are in place for collectingand maintaining accurate dataregarding each loan application,loan origination, and loan purchase—for home purchase loans, homeimprovement loans, and refinancings.The individuals assigned responsibilityfor preparing and maintaining the dataunderstand the regulatory requirementsand are given the resources and toolsneeded to produce complete andaccurate data.2Appropriate record entries are madeon the LAR within thirty calendar daysafter the end of the calendar quarterin which final action occurs (such asorigination or purchase of a loan, ordenial or withdrawal of an application).For loans sold, the type of purchasermay be added later.An officer of the institution monitorsthe collection of the loan/applicationdata during the course of the year forcompliance with the reporting instruc tions and reviews the accuracy of thedata submitted to FFIEC, as the insti tution’s data processor, at year-end.The loan/application data are submit ted annually on time (by March 1 fol lowing the calendar year of the data),and the institution responds promptlyto any questions that may arise duringprocessing of the data submitted.Administrative sanctions. Given theimportance of accurate and timely sub mission of HMDA data, a violation ofthe reporting requirements may subjectthe reporting institution to administrativesanctions, including the imposition of civilmoney penalties, where applicable.
Who MustReportCoverage Criteriafor DepositoryInstitutionsCoverage CriteriaWhether a depository institution or nondepository institution1 is covered dependson its size, the extent of its business in anMSA, and whether it is in the business ofIs the institution a bank, credit union,or savings association?residential mortgage lending. The precisecoverage criteria, set out in the definitionof “financial institution” in § 1003.2 ofRegulation C, are illustrated by the follow ing diagrams.NOSee next pageYESOn the preceding December 31,did the total assets of the institutionexceed the coverage threshold?2NOIt is exemptYESOn the preceding December 31, didthe institution have a home or branchoffice in an MSA?3NOIt is exemptYES1Unless context suggestotherwise, the Guide uses theterm “depository institutions”to apply to banks and savingsassociations (as those termsare defined in the FederalDeposit Insurance Act) andcredit unions that make feder ally related mortgage loans,and the term “nondepositoryinstitutions” to apply to othermortgage lending institutions.These common usages differfrom section 303 of HMDA,which generally defines all ofthese institutions as “deposi tory institutions.”2Every December, the Con sumer Financial ProtectionBureau will announce thethreshold for the following yearin the Federal Register. Theasset threshold may changefrom year to year based onchanges in the Consumer PriceIndex for Urban Wage Earnersand Clerical Workers.3See the next subchapter forthe definition of a “branchoffice.”In the preceding calendar year, didthe institution originate at least onehome purchase loan (excluding tem porary financing such as a construc tion loan) or refinancing of a homepurchase loan secured by a first lienon a one- to-four-family dwelling?NOIt is exemptYESIs the institution federally insured orregulated; was the mortgage loaninsured, guaranteed, or supple mented by a federal agency; or wasthe loan intended for sale to FannieMae or Freddie Mac?NOIt is exemptYESHMDA Applies to LoanOriginations, Purchases, andApplications in the CurrentCalendar Year3
Coverage Criteriafor OtherMortgage LendingInstitutionsIs the lender a for-profit institution(other than a bank, savings associa tion, or credit union)?NOIt is exemptYESIn the preceding calendar year, didthe institution's home purchaseloan originations (including refi nancings of home purchase loans)equal or exceed 10 percent of itstotal loan originations, measuredin dollars, or equal 25 million ormore?NOIt is exemptYESDid the institution either:(1) have a home or branch office4 inan MSA on the preceding December31, or (2) receive applications for,originate, or purchase five or morehome purchase loans, homeimprovement loans, or refinancingson property located in an MSA in thepreceding calendar year?NOIt is exemptYESDid the institution either:(1) have assets (when combined withthe assets of any parent corporation)exceeding 10 million on thepreceding December 31, or(2) originate* 100 or more homepurchase loans (including refinanc ings of home purchase loans) in thepreceding calendar year?YES* See comment 1003.2 (Finan cial institution)-4, Appendix D ofthis Guide.4See the next subchapter forthe definition of a “branchoffice.”4HMDA Applies to LoanOriginations, Purchases, andApplications in the CurrentCalendar YearNOIt is exempt
Who Must ReportDefinition of a“Branch Office”The term “branch office” appears in thecoverage criteria for both depository andnondepository institutions. The term refersto offices of your institution, not to officesof affiliates or of other parties such asloan brokers. As defined in Regulation C§ 1003.2, the term “branch office” has dif ferent meanings for depository institutionsand for nondepository institutions.For a bank or other depository institution,branch office means an office approved asa branch by a supervisory agency (exceptthat a branch office of a credit union isany office where member accounts areestablished or loans are made, whetheror not the office has been approved as abranch by a federal or state supervisoryagency). The term does not include otheroffices where the institution merely takesloan applications, nor does it include auto mated teller machines (ATMs).For other types of institutions, such asmortgage companies, branch officerefers to any office that takes applicationsfrom the public for home purchase loans,home improvement loans, or refinancings.Each of those institutions also is consid ered to have a branch office in any MSAor Metropolitan Division (MD) where in thepreceding year the institution receivedapplications for, originated, or purchasedfive or more loans for home purchase,home improvement or refinancing relatedto property located in that MSA (or MD)—whether or not the institution had a physi cal office there. As a result, a nondeposi tory lender not covered by HMDA in thecurrent calendar year must keep sufficientgeographic records of lending in the cur rent calendar year to determine whether itis covered in the following year.Mergers and AcquisitionsWhen a merger or an acquisition of abranch takes place, questions often ariseabout how and when to report HMDAdata. The five scenarios described belowshould answer many questions. Youcan refer other questions to your federalHMDA reporting agency for resolution.Two institutions merge, producing asuccessor institution whose assetsexceed the asset threshold for cover age. Both were previously exemptbecause of asset size. The successorinstitution’s first HMDA data collectionwill be for the calendar year followingthe year of the merger. No data col lection is required for the year of themerger.Two institutions merge, one coveredand one exempt. The covered institu tion is the surviving institution. For theyear of the merger, data collectionfor loan applications, originations,and purchases is required for the cov ered institution’s transactions, butis optional for transactions handledin offices of the previously exemptinstitution.Two institutions merge, one coveredand one exempt. The exempt institution is the surviving institution, or anew institution is formed. Data col lection for loan applications, origina tions, and purchases is required fortransactions of the covered institutionthat take place prior to the merger.Data collection is optional for transac tions taking place after the mergerdate.Two covered institutions merge. Thesurviving or resulting institution mustreport complete data for the year inwhich the merger occurred; the insti tution has the option of filing a con solidated report or separate reportsfor that year.5
Who Must ReportIf the institutions reported under differ ent agency codes before the merger,the reports for the year in which theymerged and all subsequent reportsmust be submitted under the agencycodes designated by the HMDAreporting agency of the surviving orresulting institution.For guidance on the Respondent ID(RID) number and agency code to usefor HMDA reports in merger situations,e-mail the details of the merger toHMDAHELP@frb.gov.A covered institution purchasesHMDA-related loans in bulk fromanother entity (for example, from a fail ing institution). As neither a merger noran acquisition of a branch is involved,the purchasing institution must reportthose loans as “purchased loans.”6Exemptions Based onState LawState chartered institutions located in astate that has enacted a mortgage disclo sure law may be granted an exemptionfrom HMDA if they are subject to state lawrequirements that are substantially similarto federal requirements and there are ade quate provisions for enforcement. Thoseinstitutions will submit the required infor mation to their state supervisory agency.Institutions will be informed by their statesupervisory agency when such an exemp tion has been granted.Brokered or CorrespondentLoans: Who Reports?When a covered institution makes a loanthrough a third party such as a broker,the institution, rather than the third party,reports the loan if the institution makes thecredit decision. Data on loan applicationsthat do not result in an origination mustalso be reported by the entity that makesthe credit decision. Consult comments1003.1(c)-2 through -7 (Appendix D to thisGuide) for more guidance.
DataReportingIn GeneralThe Loan/ApplicationRegister (LAR)HMDA requires covered institutions tocompile and disclose on a calendar-yearbasis data about applications for, origina tions of, and purchases of home purchaseloans, home improvement loans, and refi nancings. Information about each applica tion or loan, and about each applicant orborrower, is reported on a loan-by-loan,application-by-application basis on a loan/application register (LAR, or register). TheLAR must be completed in accordancewith Regulation C (Appendices A–C to thisGuide) and the commentary (Appendix Dto this Guide).Appendix A to Regulation C (AppendixA to this Guide) prescribes the format ofthe LAR, including the fields' names, sizes,and order. An electronic copy of the LARis available at www.ffiec.gov/hmda. Youneed not use the form that appears in theappendix,
All columns (except Reasons for Denial) must be completed for each entry. See the instru . Example of Application Denied 03/20/2012 . A GUIDE TO. HMDA Reporting . Getting It Right! Edition effective January 1, 2013 (for HMDA submissions due March 1, 2014 or later)
Fair Lending & HMDA Sunday, Sept. 18, 2016, 4:45 pm Moderator: Richard H. Harvey, Jr., Chief Compliance Officer, Colonial Savings, F.A. . Early reviews will help identify training gaps based on the results of data accuracy. Also, for the next couple of years, updated HMDA Data input
3 2020 REPORTABLE HMDA DATA: A REGULATORY AND REPORTING OVERVIEW REFERENCE CHART - VERSION 1.1, OCTOBER 16, 2020 . Data point Regulation C references Description Filing instructions b Reporting "Not Applicable" c or "Exempt" d NULI. If not reporting a ULI per the 2018 HMDA Rule, assign and report a NULI that: 1.
A submission has been created and is ready for file upload. File Now Refile This Guide is current as of January 2020 and has not been updated to reflect amendments made to Regulation C by the 2020 HMDA thresholds final rule issued by the Bureau in April 2020. For more information on the HMDA thresholds final rule, see
The PowerPoint slides and corresponding transcript from the webinar are provided on. the following pages. A recording of this webinar is located at. . including staff training and information technology changes related to first- time HMDA reporting. HMDA Webinar 1 Transcript 35
HMDA Data Collected in 2021 a This chart is intended to be used as a reference tool for data points required to be collected, recorded, and reported under Regulation C, as amended by the HMDA Rules issued on October 15,
A financial institution must retain its full (unmodified) HMDA-LAR for at least three years for examination purposes. It must also be prepared to make each modified HMDA-LAR available for three years and each FFIEC disclosure statement available for five years.
loan records and then laboriously geocode them — that is, assign them to census tracts. A check with our regions last week showed that HMDA is most heavily used by our examiners in the New York, Chicago and other big-city regions. We find that HMDA is primarily an urban tool. Our examiners use HMDA data in three ways in connection with CRA.
dance with Practices C 31, C 192, C 617 and C 1231 and Test Methods C 42 and C 873. 4.3 The results of this test method are used as a basis for 1 This test method is under the jurisdiction of ASTM Committee C09 on quality control of concrete proportioning, mixing, and placing
