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Newly Covered by HMDA

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We have opened a branch in a metropolitan area this week. We are now HMDA reportable. When do we begin maintaining the LAR now or January 1st of 2003? Also, we are still classified as a small bank with assets less than $250,000 when we begin maintaining the LAR do we do it for all branches or just for the branch in the metropolitan area?

Congratulations, you are in for a treat! Section 203.3(a) says that you must begin complying with HMDA on 1/1/03 if you have a branch in a MSA beginning in 2002. Do not start now, but start getting ready. When your bank becomes subject to HMDA, all applicable applications must be reported, regardless of the branch location.

You need to receive some training on HMDA, as it is quite complex. First, start by reading Regulation C and the commentary. Get the book called "HMDA Getting It Right" from the FFIEC (you can even download it from the ffiec website. In fact, go to the FFIEC HMDA website to learn about HMDA. Also, call you regulator and tell them you are getting ready for HMDA. They may provide some guidance and software to assist you. Good luck.

First published on 6/17/02

First published on 06/17/2002

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