We are an ISB and purchased HMDA reportable loans we are adding to our LAR. The appendix in HMDA allows monitoring info (race, sex, ethnicity) to be reported as NA. All of the purchased loans are secured by homes not located in our assessment area. Is there a reason to go the extra step and report monitoring info? To assist with minimizing HMDA error potential my initial thought is to report NA for GMI, but if there is a CRA reason to report I would do so.

With the regulators applying REMA (which is not defined in the regulations) there is always the potential that the loans outside your AA may be considered by examiners for Fair Lending purposes. So if the loans are outside your AA, but nearby you may see examiners include them for Fair Lending purposes and redlining analysis in particular. We've seen that happen to a number of clients in recent years.

Aside from race, ethnicity and sex I assume you are also omitting income?

Do you have any idea of what the data would look like if you did record and report the GMI fields?

I agree with you about the REMA. We have reviewed our HMDA loans to come up with our REMA, so we have at least a starting point for that, of course subject to the examiners' opinions. All of the purchased loans are outside our CRA AA. All of the purchased loans are also outside our REMA except 1. The 1 loan in our REMA is not in a low or moderate CT, nor is the CT a high minority CT. The loan is not to a low or moderate income individual.

Yes, we are omitting income.

No, I don't know what the GMI field content is at this time for all of the loans, although we have the applications and can get it for the HMDA LAR if need be. I was just trying to cut down on errors, and if none of the loans are in our AA, and only 1 in our REMA, I am not sure it is worth the extra effort, and I am not sure that it would really be considered during an exam if those loans are not in our AA. The 1 in our REMA might, but it's location does not help with LMI and high minority CT penetration.

Trying to keep HMDA clean but help CRA in any way we can. ???