A Guide to HMDA Reporting - ffiec

Who Must Report If the institutions reported to different
agencies before the merger, the
reports for the year in which they
merged and all subsequent reports
must be submitted to the agency
designated by the supervisory
agency of the surviving or resulting
institution to receive that institution's
data.
6
For guidance on the Respondent ID
(RID) number and agency code to
use for HMDA reports in merger situations,
e-mail the details of the
merger to HMDAHELP@frb.gov.
¢ A covered institution purchases
HMDA-related loans in bulk from
another entity (for example, from a
failing institution). As neither a
merger with nor acquisition of an
institution, nor an acquisition of a
branch, is involved, the purchasing
institution must report those loans as
“purchased loans.”
Exemptions Based on
State Law
State chartered institutions located in a
state that has enacted a mortgage disclosure
law may be granted an exemption
from HMDA if they are subject to
state law requirements that are substantially
similar to federal requirements
and there are adequate provisions for
enforcement. Those institutions will submit
the required information to their state
supervisory agency. Institutions will be
informed by their state supervisory
agency when such an exemption has
been granted. As of publication, no state
exemptions are in effect.
Brokered or Correspondent
Loans: Who Reports?
When a covered institution makes a loan
through a third party such as a broker,
the institution, rather than the third party,
reports the loan if the institution makes
the credit decision. Data on loan applications
that do not result in an origination
must also be reported by the entity
that makes the credit decision. Consult
staff comments 203.1(c)-2 through -7 for
more guidance.