Our bank is currently not subject to HMDA reporting. If we open a loan production office in a metropolitan statistical area, would this make us a required HMDA reporter?
Our bank operates branches in multiple counties throughout the state. This fall, two of our coastal branches will be chartered into their own bank. We will no longer report their HMDA loans after their conversion date. Is there any reason we would not report the loans from January 1st until their conversion date on the lead bank's LAR? Will the new bank have to report their HMDA loans from conversion to December 31st if their asset size is over the threshold? My thought process tells me no since they would not have had any assets of their "own" for the prior two years. They will be located in an MSA and will have initial assets over the threshold.
We are considering extending our CRA assessment area to include a portion of the surrounding counties. None of these areas is a MSA or considered distressed. What, if any, compliance issues would we face doing this? Also, is there a maximum percentage of our loans that can be outside our assessment area?
The 2004 HMDA data is finally out and the numbers show what we expected and feared: Black Americans fare less well in the mortgage market than non-Hispanic whites. Now what?
The U.S. Department of Justice is working hard at fair lending enforcement. This is not a concern that has faded into the background. Quite the opposite is true.
HMDA MSA Boundaries
Answer by Mary Beth Guard, BOL Guru
Should we be reporting a HMDA code "3" in the owner occupancy category when the property location is not in an MSA, or can we report a "1 - owner occupied" or "2 - not owner occupied"?
At PCi's annual User Conference, several speakers shared their ideas for the transition to new HMDA. First, be prepared for last minute change.
We have an affordable loan program that is specifically geared towards minorities, females, household incomes that are less that 80% of HUD's MSA Median Family Income, a property located in a low income census tract or that is considered mostly minority and a first time homebuyer that does not meet any of the above -- any of these individuals will receive an 1/8% rate reduction. Are there any fair lending/CRA issues that we need to be concerned about?
You have two months to get your HMDA report entered, checked, corrected, and sent in. And that's on top of all the Y2K activities.