It's been over 15 years since I have had to deal with a large bank for CRA purposes so I am brushing up. Regarding what has to be reported annually, I am unclear about the HMDA information for a HMDA bank. Specifically, the following from the FFIEC CRA "(3) Home mortgage loans. If the bank is subject to reporting under part 203 of this chapter, the location of each home mortgage loan application, origination, or purchase outside the MSAs in which the bank has a home or branch office (or outside any MSA) in accordance with the requirements of part 203 of this chapter." Does this mean that the CRA Loan Register needs to include this information or just that if you are also a HMDA bank, that you have your HMDA LAR updated with this information?

Maybe I didn't do a good job at asking my question. For anyone that is a CRA Large Bank and reporting data, what exactly are your reporting in terms of anything to do with HMDA? I appreciate any input.

Your question is a bit confusing but I will try to answer it as I understand it.

There are certain exceptions regarding geocoding loan applications under HMDA which allow a lender to enter "NA" for records that are not located in an MSA, or MD in which the lender has a home or branch office unless the lender is required to report loan data under CRA in which case the geocoding exemption for HMDA applications does not apply.

So CRA can trigger a more exacting geocoding responsibility for CRA reporters. But the HMDA data is not reported under CRA. It is reported under HMDA. When your bank is examined for CRA purposes the examiners will collect the data you have reported under HMDA and incorporate it with the data you reported under CRA for examination purposes.

I think that answers your question. You can always pm me if you want to speak directly.