We are usually a HMDA bank but in 2015 and 2016 made fewer than 25 loans each year. Does anybody have a pdf of the Fair Housing Home Loan data log or would it be easier to still do HMDA this year?

The FH Home Loan data log applies only if:

a. Your institution is regulated by the OCC;
b. The bank is NOT subject to HMDA; and,
c. Your bank receives 50 or more home loan applications a year (purchase, permanent financing for construction or the refinancing of residential real property which the applicant intends to occupy as a principal residence).

12 CFR 27.2(a)(2) - OCC regulated banks only

A Comptroller of the Currency monthly home loan activity format is shown in Appendix I to 12 CFR 27. These forms may be obtained from the OCC Regional offices.

I'm confused on the change. We are new to HMDA and 2017 is the first year we have to report for the loans we did in 2016. So we are just getting our brains wrapped around the old way of doing HMDA.

So for 2017, what is the criteria for having to report? 25 purchase loans actually originated? We don't do HELOCs. Is it 25 loans that were purchase for 2016 and 25 loans that were purchase for 2015?

Here's a flowchart from the CFPB for 2017 coverage:
http://files.consumerfinance.gov/f/201510_cfpb_2017-hmda-institutional-coverage.pdf

You can find the 2018 flowchart (and other aids) at their website - under "Quick References":
https://www.consumerfinance.gov/policy-c...implementation/

Thanks David, I had looked at that. What I'm hung up on, is it 25 total over the 2 year span or 25 loans per year, so a total of 50 over the 2 year span?

In each of the two preceding calendar years, did the institution originate at least 25 home purchase loans, including refinancings of home purchase loans2

It's 25 per year.

Dan is correct. In calculating the 25 loans for 2017, you use the current coverage rules and exemptions. However, in 2018, you'll look back at 2016 and 2017 using the new coverage & exemptions. IOW, you can't look at today's and last year's LAR to determine if you are subject to HMDA in 2018!

Thanks guys! Also for 2017, with the 25, since we were not subject to HMDA, we don't have the data compiled for 2015 loans, so do we need to go back through our loans for 2015 and try to figure out which ones were Purchase or refinance of a purchase? Also does refinance of a purchase count any refinance that we reported? We are primarily an AG bank and do a lot of AG loans where we take the "farm" as an abundance of caution. So when they pay one loan off and get another one to purchase equipment or operating funds, this gets pulled in as a refinance since it includes their home. Do these count as a refinance of a purchase towards the 25?

Also for 2017, with the 25, since we were not subject to HMDA, we don't have the data compiled for 2015 loans, so do we need to go back through our loans for 2015 and try to figure out which ones were Purchase or refinance of a purchase?
Yes.

Also does refinance of a purchase count any refinance that we reported?
Look at the CFPB flowchart I posted on 2/23 (here it is again). It's only purchases and refinances of purchases - not any refinancing.
http://files.consumerfinance.gov/f/201510_cfpb_2017-hmda-institutional-coverage.pdf

Thank you so much David.