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#1997734 - 02/24/15 03:18 AM HMDA MSAs
Night Train Offline
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Night Train
Joined: Sep 2006
Posts: 1,189
Down South
Question - if we have a branch location in an MSA county and that MSA contains multiple counties, do we report all loans in all counties of that MSA or just the ones in the county where our branch is located?

All assistance will be appreciated.

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#1997735 - 02/24/15 03:53 AM Re: HMDA MSAs Night Train
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
If you have triggered HMDA reporting by asset size, the loans you have made, and by having a branch in an MSA, you report all loans that are HMDA reportable, no matter where the property related to the loan is located.
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#1997736 - 02/24/15 04:26 AM Re: HMDA MSAs Night Train
Truffle Royale Offline

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Posts: 17,395
Keep in mind that the GIR, p.13, states that, with regard to geocoding:
Quote:
If the property is located outside the MSAs where you have a home or branch office (or outside any MSA) and you are not required to report data under the Community Reinvestment Act (CRA), you may enter the applicable codes or you may enter “NA” in every column.


This is one of the items that may change with the CFPB gets around to the new HMDA data collection rules.

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#1997752 - 02/24/15 02:14 PM Re: HMDA MSAs Night Train
Night Train Offline
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Night Train
Joined: Sep 2006
Posts: 1,189
Down South
Right - I know that we have to report all loans that are HMDA reportable because of our size and that we have branch locations in MSAs. My original question wasn't completely clear and I apologize. To refine it - we have a branch location in county A which is in a MSA. That particular MSA # also contains counties B, C, D, & E. Do we have to report counties B thru E as being in a MSA the same as we do for county A? In other words - do we have to report everything within that MSA or segment it by county within?

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#1997755 - 02/24/15 02:25 PM Re: HMDA MSAs Night Train
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
If you have an office in a MSA you report the required information for all reportable loans made in that MSA. Loans made outside the MSA you have an option, see TR's response.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1997758 - 02/24/15 02:36 PM Re: HMDA MSAs Night Train
Night Train Offline
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Night Train
Joined: Sep 2006
Posts: 1,189
Down South
Thank you all so much! I appreciate your help in clarifying this for me.

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