2008 HMDA Data Released
By Amy Kudlacek
The 2008 HMDA Data has been released (finally!). This is the latest I have ever seen this data come from the FFIEC. Here is the press release from the FFIEC. You can download your disclosure statement (or those of other banks) here. And finally, you can download aggregate data by state by clicking here.
Don't forget to update your CRA file with this information. §345.43(b)(2) (the FDIC's version of the CRA rules - but all regulators have the same requirement) state:
"A bank required to report HMDA data shall include in its public file a copy of the HMDA Disclosure Statement provided by the Federal Financial Institutions Examination Council pertaining to the bank for each of the prior two calendar years. In addition, a bank that elected to have the FDIC (Federal Reserve/OCC/OTS) consider the mortgage lending of an affiliate for any of these years shall include in its public file the affiliate's HMDA Disclosure Statement for those years. The bank shall place the statement(s) in the public file within three business days after receipt."
§203.5 of Regulation C (HMDA) also states:
(2) An institution shall make its disclosure statement (prepared by the FFIEC) available to the public at its home office no later than three business days after receiving it from the FFIEC.
(3) In addition, an institution shall either:
(i) Make its disclosure statement available to the public, within ten business days of receiving it, in at least one branch office in each other MSA and each other Metropolitan Division where the institution has offices (the disclosure statement need only contain data relating to the MSA or Metropolitan Division where the branch is located); or
(ii) Post the address for sending written requests in the lobby of each branch office in other MSAs and Metropolitan Divisions where the institution has offices; and mail or deliver a copy of the disclosure statement within fifteen calendar days of receiving a written request (the disclosure statement need only contain data relating to the MSA or Metropolitan Division for which the request is made). Including the address in the general notice required under paragraph (e) of this section satisfies this requirement.
The disclosure statement at a branch office need only contain data relating to properties in the MSA where the branch office is located. You do not need to print the HDMA data. We recommend you burn it to a CD, DVD or USB stick and simply put this in the file. When (or should we say "if") someone ever asks for it, you can print it for them at that time.
Have fun!