FFIEC Issues Additional Guidance on HMDA Reporting

Several Regulation C amendments that were adopted in 2002 took effect Jan. 1, 2004—the first year the new data must be reported. Based on analysis of some preliminary 2004 data, the Federal Financial Institutions Examination Council (FFIEC) believes that Home Mortgage Disclosure Act (HMDA) reporters need additional guidance to ensure that the data they report are accurate.

The additional guidance pertains to:

  • transition rules;
  • ethnicity, race and sex (government monitoring information);
  • property location information on refinancings and pre-approvals;
  • lien status reporting;
  • loans subject to the Home Ownership and Equity Protection Act (HOEPA loans); and reporting the sale of home purchase loans.

The transition rules cover fields including ethnicity, race and sex for applicants and co-applicants. Ethnicity is a new field that was added to the HMDA Loan Application Register (LAR) beginning Jan. 1, 2004. An applicant and/or co-applicant can designate up to five racial designations. Institutions must report a code in both the ethnicity field and at least the first race field for both the applicant and co-applicant on every LAR record.

The 2004 reporting deadline was March 1, 2005. In the coming months, be on the lookout for edit reports, which are used to verify data accuracy, and your institution’s disclosure statement—available in early third quarter.

Complete guidance can be found on the FFIEC’s web site, www.ffiec.gov/hmda/pdf/FFIECguidance2004.pdf. If you have any questions about the new guidance, contact Bob Dowling at (314) 444-8532.

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