I, like many of you, wear many hats. Unfortunately, the person who was our CRA Officer has decided not to return after a medical leave and will be caring for a new child. This means that the bank will not be able to advertise and recruit for this position in time to ensure that we have everything HMDA-wise completed by January 1, 2004. I am a financial-type person, and have been away from HMDA's issues for quite some time.

Can anyone share with me in a "non-Greek" version what actual reporting changes MUST be in place by 01-01-04. I know that our people will be asking and gathering the ethnicity information as a separate standalone question; however, I'm just not sure what else we need to change in our reporting. We don't do "high cost" loans, and our geocoding is sent out to a well-known vendor (I won't name, because that's not a factor). Can anyone share with me in a "non-Greek" version what actual reporting changes (other than the ethnicity change)need to be reported by us to our HMDA vendor in order to geocode by 1-1-04? I appreciate any comments, suggestions, links, etc.

This is a nice site that I only recently learned of, and after dealing with this CRA issue I'm ready for the "WaterCooler" thread.

GLJ

I found the power point presentation on the FFIEC website to be helpful. Here is the link:
HMDA Powerpoint
The St. Louis Federal Reserve also has a website dedicated to the HMDA changes for 2004.
HMDA Amendments FRB Website

Go to www.stlouisfed.org. They have all information you will need including a really nice Q&A.

Depending on your volume/needs, you may consider outsourcing and getting a trainer in to bring everyone up to speed and fill in some gaps in the interim.

You have some good resources already listed. Now you just need the time to learn what they say. Time is the tough part.

Anon, Just had to share a nifty little tool that I found HMDA Cheat Sheet courtesy of QuestSoft -- thank you. They are a BOL vendor and I am not connected with them in any way. Perhaps this will be a good starting point for you if you are keeping this in-house.

One of the major changes is the rate spread calculation.

See Appendix A. This text is on Page 17 of 24 page document. http://www.ffiec.gov/hmda/pdf/regulationc2004.pdf

G. Pricing-Related Data.

1. Rate Spread.

a. For a home purchase loan, a refinancing, or a dwelling-secured home
improvement loan that you originated, report the spread between the annual
percentage rate (APR) and the applicable Treasury yield if the spread is equal to
or greater than 3 percentage points for first-lien loans or 5 percentage points for
subordinate-lien loans. To determine whether the rate spread meets this threshold,
use the Treasury yield for securities of a comparable period of maturity as of the
15th day of a given month, depending on when the interest rate was set, and use
the APR for the loan, as calculated and disclosed to the consumer under section
226.6 or 226.18 of Regulation Z (12 CFR part 226). Use the 15th day of a given
month for any loan on which the interest rate was set on or after that 15th day
through the 14th day of the next month. (For example, if the rate is set on
September 17, 2004, use the Treasury yield as of September 15, 2004; if the
interest rate is set on September 3, 2004, use the Treasury yield as of August 15,
2004). To determine the applicable Treasury security yield, the financial
institution must use the table published on the FFIEC's web site
(http://www.ffiec.gov/hmda) entitled “Treasury Securities of Comparable
Maturity under Regulation C.”
b. If the loan is not subject to Regulation Z, or is a home improvement loan that
is not dwelling-secured, or is a loan that you purchased, enter “NA.”
c. Enter “NA” in the case of an application that does not result in a loan
origination.
d. Enter the rate spread to two decimal places, and use a leading zero. For
example, enter 03.29. If the difference between the APR and the Treasury yield is
a figure with more than two decimal places, round the figure or truncate the digits
beyond two decimal places.