As a non-HMDA reporting bank, 12 CFR 27.3 requires us to keep statistics on home loan applications. With the inclusion of preapprovals in the new definition of "application", will we include these also?

HMDA has changed to include a column for applications that started as preapprovals, but that doesn't mean that you will record all preapprovals. Second, HMDA has changed, but the OCC's Fair Housing Act hasn't. If you are subject to HMDA, you don't have to keep the OCC's Fair Housing log.

I would believe that areal minority of banks use the FHHLDS to follow applicable mortgage loans. But there is some interest based on some recent posts here and bankers discussions at the TBA school.

Ask your regulator if they anticipate changes let us know. Thx.

I was referring to the recent change to Reg B. I'll have to read up on Reg C changes. I just read a short portion of a recent seminar that stated "Reg C has been revised to include preapprovals" and assumed it was straightforward.

12 CFR 27.3 (1) seemed to be duplicative of Reg C (Section 203). As an exception, 2.3 (2) required recording and maintaining similar information ("home loan applications"). I'll check with my local OCC regulator and tell you what they said.