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Threshold for HMDA

Answered by: 
David A. Dickinson

Question: 
If depository institutions with asset sizes less than $29MM less are exempt from reporting, then why does <a href="http://www.ffiec.gov/hmda/guide.htm">HMDA Getting It Right</a>, page 11, mention that bank, thrift, or credit unions (depository institutions, right?) with less than $30MM in assets are not required to report race, sex and income. Wouldn't they be exempt from reporting anyway? Is the reg really calling for a different requirement for institutions with assets between $29MM and $30MM?
Answer: 

Section 203.3(a) sets the threshold for HMDA exemptions. Currently, it says that a bank with total assets of $28 as of December 31, 1996 do not need to report HMDA information. This number is adjusted each year and is $32 million for 2002. [see 203.3(a)(2). When the "Getting It Right" book was printed, the dollar threshold was $29 million.

First published on BankersOnline.com 6/17/02

First published on 06/17/2002

Filed under: 
Compliance
Filed under compliance as: 
HMDA
IT
Reporting

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