We are a rural community bank and have never been HMDA reportable. We just hired a Loan Officer that will be on the road going to MSA areas, does that make us HMDA reportable?

The information you've given us is insufficient to answer your question.

Pull up the Getting It Right! guide and read the first few pages. There's a yes/no table in there that should help you determine your Reg C accountability.

Take a look at Reg. C Section 203.2(e) for coverage rules.

And no questions are stupid questions! We are all here to help one another.

^^^what she said about stupid questions.

Also, please read the first post in this forum. It would help if your post title was such that it would come up in a search by the next person with the same question.

Thanks!

If I'm understanding the OP's question, it doesn't sound like your HMDA reporting or non-reporting status will have changed simply because you have a LO who travels to MSAs. You need to have a home or branch office in an MSA to meet that part of the test.