When HMDA Applies

Question:

For HMDA reporting requirements, I am aware that a bank with an office in a MSA or PMSA must report. I am needing to know the parameters concerning the MSA or PMSA and distance requirements. I know that there used to be an explanation concerning this in the HMDA regulation concerning number of miles surrounding an MSA. If your bank or branch was within so many miles from an MSA, you were covered by the regulation. I cannot find in the regulation where the mileage is stated. I am thinking that it is 25 miles, but I cannot find that information. Your assistance will be appreciated.

Answer:

HMDA applies if a financial institution has a branch in a MA (Metropolitan Area - the new term that replaces MSA and the even older SMSA). A forprofit mortgagelending institution is deemed to have a branch office in a metropolitan area if it receives applications for, originated, or purchased five or more home purchase loans, home improvement loans, or refinancings related to property located in that metropolitan area.

I have been dealing with Regulation C since the day it was born, and I do not recall the mileage inclusion rule you mention. Of course, some days I wake up and don’t remember what city I am in either. But there is definitely no such rule in the regulation at present, or as revised effective January 1, 2003.

First published on BankersOnline.com 6/3/02