HMDA Data Requests
By David Dickinson
We are hearing that many banks have recently had requests for their HMDA Data. While you are required to make this information available, you are not required to provide it for free or provide the data electronically.
Section 203.5(d) of HMDA states:
"Availability of data. A financial institution shall make its modified register available to the public for a period of three years and its disclosure statement available for a period of five years. An institution shall make the data available for inspection and copying during the hours the office is normally open to the public for business. It may impose a reasonable fee for any cost incurred in providing or reproducing the data."
People that request your HMDA data are most likely trying to analyze it to identify illegal discrimination. Don't make this an easy process! I recommend you only make this information available in paper form. You also are not required to copy the data for them, but can simply "make it available for . . . copying". I'm not certain what a "reasonable fee" is, but you certainly can require the requester to reimburse for the use of your copier, the paper expense and the time of the employee assisting with the request. In other words, make this process as difficult as possible. Most requesters will back away when you charge a fee and won't provide it electronically.
One more caution: Don't EVER provide your full LAR. Be sure to provide the Modified LAR which eliminates many columns of the data. You are not allowed to release your full LAR to the public.