We have never needed to file HMDA data up to this point, so I went to the FFIEC to determine if we should file for 2011..and after reading the instructions, it appears clear as mud... but perhaps I am over thinking this.. The FFIEC site says


Use information and data from the preceding December 31 date when determining whether you meet the reporting criteria. The following questions for a depository institution should be answered to determine if you should report CY 2011 HMDA data in 2012.
Does this mean using information from 2010? So, where it says did you originate at least one home purchase loan in 2010 or is it 2011..to determine filing for 2011 by March of 2012. I am soo thick!

Is the depository institution a bank, credit union, or savings association?
Did the assets of the institution total more than $40 million on the preceding December 31?
Did the institution have a home or branch office in a metropolitan statistical area or metropolitan division (MSA/MD) on the preceding December 31?
In the preceding calendar year, did the institution originate at least one home purchase loan or refinancing of a home purchase loan secured by a first lien on a one-to-four-family dwelling?
Is the institution federally insured or regulated; or was the mortgage loan insured; guaranteed, or supplemented by a federal agency; or was the loan intended for sale to the Federal National Mortgage Association (FNMA) or Federal Home Loan Mortgage Corporation (FHLMC)?


If a depository institution responds 'YES' to the above questions 1 through 4 and 'YES' to at least one question in 5, then HMDA applies to the institution's loan originations, purchases, and applications in the current calendar year. A negative response to any one of the first four questions or to all the questions in 5 would exempt the institution from filing HMDA.


Thank you for your help!

And your question is...?????

When you are trying to decide if you must file, what year is the "preceding December 31 date "

For example, we made 1 loan that is HMDA reportable in 2010, should we have filed in March 2011... or will we need to file in 2011 data by March 2012..

It is the preceding language that is confusing....


Use information and data from the preceding December 31 date when determining whether you meet the reporting criteria. The following questions for a depository institution should be answered to determine if you should report CY 2011 HMDA data in 2012.
Does this mean using information from 2010? So, where it says did you originate at least one home purchase loan in 2010 or is it 2011..to determine filing for 2011 by March of 2012. I am soo thick!

Dec 31, 2010 would be the preceding year for the 2011 filing.

If you met the coverage criteria in 2010 then as of Jan 1, 2011 you should have started collecting data in order to report it on or before Mar 1, 2012. If you did not meet the coverage criteria as of Dec 31, 2011 you would stop collecting the data for 2012.

I am sorry I am so thick... so continuing on with the scenario, if we had no reportable applications again in 2011, then we would file 0 for 2011, and stop collecting in 2012...

When would/should we report the 1 loan for 2010 then?

You would have reported it by 3/1/11 if you met the asset threshold as of 12/31/09.

Thank you for your help!