If a bank receives regulatory approval in 2004 to open a branch in a MSA, but does not open the branch until the following year (2005), when is the bank subject to HMDA? Part 203.3(a)(i) says that an institution is exempt from the requirements of Reg C for a given calendar year if on the preceding December 31 the institution had neither a home office nor a branch office in an MSA. Part 203.2 defines branch office as "any office of a bank, savings association, or credit union that is approved as a branch by a federal or state supervisory agency, but excludes free-standing electronic terminals such as automated teller machines". Does the office have to be open for business on December 31st, 2004 for the bank to be subject to HMDA reporting requirements on January 1, 2005?
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