Will You Be A HMDA Bank in 2014?

Just in case you missed it, the Office of Management and Budget announced revisions affecting areas Amy11designated as Metropolitan Statistical Areas, Metropolitan Statistical Areas and Combined Statistical Areas back in February.  You might be thinking, “who cares?”  The answer is, you might.

Areas designated as Metropolitan Statistical Areas (MSAs) are one of the key components in determining whether you bank is subject to the Home Mortgage Disclosure Act (HMDA).  HMDA is one of the most difficult compliance regulations.  It takes A LOT of training for your personnel, process/procedure development and imposes civil money penalties for non-compliance.

The announcement contains many different lists of information; however, you should be mostly concerned with “List 2”.  It provides information such as the MSA’s codes, principal cities, counties, etc.  If your bank has locations in more than one state, you will want to check the MSAs for each state.

Let’s look at an example for the state of Nebraska, as that is where our home office is located.

List 2 shows three MSAs for Nebraska (see below).  These are Grand Island, NE, Lincoln, NE and Omaha, NE/Council Bluffs, IA.  You will notice that each MSA includes not only the city but also the county and even some surrounding counties.

24260  Grand Island, NE  Metropolitan Statistical Area

Principal City: Grand Island

Hall County, Hamilton County, Howard County, Merrick County

*This MSA is new for 2014

30700  Lincoln, NE  Metropolitan Statistical Area

Principal City: Lincoln

Lancaster County, Seward County

36540  Omaha-Council Bluffs, NE-IA  Metropolitan Statistical Area

Principal Cities: Omaha, NE; Council Bluffs, IA

Harrison County, IA; Mills County, IA; Pottawattamie County, IA; Cass County, NE; Douglas County, NE; Sarpy County, NE; Saunders County, NE; Washington County, NE

If a bank has assets of $42 million or more (this threshold changes periodically) AND has a main office or branch located in one of these MSAs, the bank is subject to HMDA.

The revisions were effective immediately; however banks brand new to HMDA (as a result of the revisions) will begin collecting and reporting HMDA data on applications taken on or after January 1, 2014.

Now is the time to determine if these revisions will affect you.  If they do, you need to begin learning all you can about HMDA and developing a plan to train your personnel.

Amy Kudlacek

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