Question & Answer

Question: Are there any special rules or exemptions for "small banks" (those under $250 million in assets) when it comes to data reporting under HMDA and CRA?

Answer: Beginning in 1996, banks having assets of at least $250 million will have to provide the census tract for all HMDA reportable loans made outside of the bank's MSA. Until now, it has not been necessary to provide the census tract for loans made outside of the MSAs. However, this requirement does not apply to banks having less than $250 million. These banks do not need to provide the census tract on loans made outside of their MSA.

Remember, the new CRA examination will be based in large part on the bank's own data. Small banks may want to include data on loan portfolios other than mortgage loans. Therefore, even if you are exempt from HMDA reporting or from the additional CRA reports, you may speed up your CRA exam by generating reports that provide basic information about your bank's lending, even if you are not required to do so. The important difference is that you can format a non-required report in any way that you want and focus on data that is useful to you in managing the compliance and CRA programs.

Copyright © 1996 Compliance Action. Originally appeared in Compliance Action, Vol. 1, No. 2, 1/96