We just bought another bank, and they told us that CRA reportable loans are not HMDA reportable. (??) I didn't think they were mutually exclusive.

Can anyone point me to the where I can find this out. please?

In the FAQ there is a lot of discussion about this topic. The only loans that can be on CRA and HMDA are multi-family and small business refis.

They do get considered in your CRA Exam because HMDA is part of that review, just not double reported.

Small business that would otherwise be excluded can be presented (not reported) as type 3 - Other Small Business.

Just in case you don't have this:


FFIEC CRA Guide

or this:

Data collection grid

Appendix B (Q&As) & Appendix D are very helpful with clarifications of the Reg.

Thanks both of you!