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Inactive Financial Institution Letters
February 13, 1996
EXECUTIVE OFFICER and
Staff Commentary on HMDA Reporting Requirements
| The Board of
Governors of the Federal Reserve (Federal Reserve) has adopted its
staff s commentary that interprets Regulation C, which implements
the Home Mortgage Disclosure Act (HMDA). The attached commentary
is being provided to all FDIC-supervised institutions because of
the interest expressed by many institutions that may become subject
to Regulation C as a result of future mergers and acquisitions.
Previously, A Guide to HMDA Reporting -- Getting It Right!, the Federal Financial Institutions Examination Council s (FFIEC) annual publication, was the only guidance available from the Federal Reserve on the requirements of Regulation C and its Appendix A, the instructional portion of the regulation. The new commentary complements Appendix A and should he read alongside it for fuller understanding. The informal presentation in the Guide will remain a helpful reference for lending institutions, especially its flow chart depicting HMDA coverage criteria, the step-by-step guidance to completion of the report form, and the table of state and county codes for counties in Metropolitan Statistical Areas (MSAs). The 1996 Guide will be mailed in March to HMDA-reporting institutions supervised by the FDIC.
The staff commentary interprets many complex data reporting issues, including:
Also, the commentary deals with two technical changes that affect the collection of data during calendar year 1996. These technical changes have resulted in two revisions to the CY96 FFIEC HMDA data collection software, which has been provided to all FDIC-supervised HMDA-reporting institutions. The changes are:
The Federal Reserve will revise the commentary as needed to include clarifications of other issues and future amendments to Regulation C. If you have questions concerning the staff commentary or other HMDA issues, Please contact your FDIC regional office.
Distribution: FDIC Supervised Banks (Commercial and Savings)
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