In reading the Guidance of MSA Boundary Changes, in the purpose section it states that “This guidance also conforms the reporting requirements for CRA loan data to previously announced reporting requirements for HMDA loan data. December 2003 HMDA regulation amendment.”

My question centers on the definition of a “Branch Office” in Regulation C wherein it states in part that “A for-profit mortgage-lending institution is also deemed to have a branch office in an MSA or in a Metropolitan Division, if, the preceding calendar year, it received applications for, originated, or purchased five or more home purchase loans, home improvement loans, or refinancings related to property located in that MSA or Metropolitan Division, respectively.” We are a CRA large bank located in a MSA. My concern is that we received 6 applications, (3 approved and 3 denied) from an MSA which is 75 miles away from us and is not part of our defined assessment area. If I have interpreted this correctly, does this mean that for this year we would have to include this MSA and all of its census tracts as a separate assessment area for CRA reporting purposes?

Don't think so; but you do have to report all geocoding data for these loans. The definition of your AA is up to your bank.

Don - You got it! Don't confuse HMDA with CRA - two totally different animals.