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FFIEC and the Reclassification of MSA Branches
Answer by Todd Cooper, EVP CRA Products, PCi Corporation
Question: On June 6, 2003, FFIEC reclassified some of the MSA branches. The branch getting us into the HMDA reporting was dropped (which means we are no longer report HMDA ....hurrah.....) My question is, how do we report the information collected prior to June 6, 2003. Do we continue to collect HMDA information past the June 6th date? And what do we report to HUD next year? I have sent this question to HUD, FFIEC and FDIC (our regulator)and I have received no guidance. I need guidance. Can you help?
Answer: If you are referring to the new OMB MSA and MD (Metropolitan Division) definitions, then you should continue reporting HMDA for 2003 because they do not got into affect until the 2004 data reporting cycle. All 2003 data should be reported under the existing MSA (or MA) geographies as they were at the beginning of the year. One thing to keep in mind is that new OMB MSA and MD geographies have a tendency to be more inclusive than the previous MSA geographies, and that it would be a rare situation that would cause a branch to fall outside a metro area, so you may want to take a closer look at the new geography definitions.
PCi Corporation is the leading provider of compliance risk management solutions that ensure financial institutions fully comply with the Community Reinvestment Act (CRA), the Home Mortgage Disclosure Act (HMDA), fair lending and anti-predatory laws, as well as the National Flood Insurance Reform Act. More than 90 of the nation's top 100 banks, numerous community banks, and many of the federal and state regulatory and enforcement agencies rely on the company's compliance products, data, and services. More information about PCi can be found at www.pciwiz.com.
First published on BankersOnline.com 8/18/03
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