HMDA Reporting - Office Isn't an Official Branch
Answer by David Dickinson, BOL Guru Guru Bio
Question: Our bank has two offices in rural areas and assets of approximately 42 million. We hired a loan officer to work in an MSA. He may be creating 1-4 family residential real estate loans or home equity loans. The office is not an official branch and is still not an official LPO. Will the bank be subject to HMDA reporting?
Answer: If it is not a "branch office" then you are not subject to HMDA. This term is defined in §203.2(c). Also, refer to the definition of "financial institution" in §203.2(e). You should discuss this with your regulator to verify your interpretation.
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