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A Guide to HMDA Reporting - ffiec

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Disclosing<br />

the Data<br />

Disclosure of a Modified LAR<br />

Institutions must make their LAR data—<br />

modified <strong>to</strong> protect privacy interests of<br />

applicants and borrowers—available <strong>to</strong><br />

the public upon request in electronic<br />

or printed form. Three fields must be<br />

deleted: the application or loan number,<br />

the date the application was<br />

received, and the date the action was<br />

taken. Aside from those three modifications,<br />

Regulation C does not permit<br />

deletions. Nor does Regulation C require<br />

any changes <strong>to</strong> the format or order of<br />

the data before their disclosure. Nevertheless,<br />

institutions are strongly encouraged<br />

<strong>to</strong> make the data available in<br />

census tract order, if possible.<br />

A modified register must be available no<br />

later than March 31 for requests made<br />

on or before March 1 following the year<br />

<strong>to</strong> which the data relate, and within 30<br />

days for requests made after March 1.<br />

The modified register must continue <strong>to</strong><br />

be made available <strong>to</strong> the public for three<br />

years.<br />

Disclosure Statements<br />

Prepared by the FFIEC<br />

Using data from each institution’s LAR,<br />

the FFIEC will prepare and post <strong>to</strong><br />

the Internet (www.<strong>ffiec</strong>.gov/hmda) a<br />

series of tables that will comprise the<br />

institution’s disclosure statement.<br />

An institution must make the statement<br />

available <strong>to</strong> the public for inspection and<br />

copying at its home office in printed or<br />

electronic form within three business<br />

days of the disclosure statement's<br />

posting <strong>to</strong> the Internet. In addition, if an<br />

institution has branch offices in other<br />

MSAs/MDs, it must make available an<br />

MSA/MD-specific disclosure in one of<br />

two ways:<br />

¢ by making the statement available in<br />

at least one branch office in every<br />

MSA/MD other than the MSA/MD of<br />

the home office, within ten business<br />

days of receipt from the FFIEC, or<br />

¢ by posting an address for requesting<br />

copies in every branch office in<br />

an MSA/MD (other than branches in<br />

the MSA/MD of the home office) and<br />

responding <strong>to</strong> written requests<br />

within fifteen calendar days.<br />

The institution may charge a reasonable<br />

fee <strong>to</strong> cover costs incurred.<br />

The disclosure statement must remain<br />

available <strong>to</strong> the public for five years,<br />

and an institution must post a notice<br />

about its availability in the lobby of its<br />

home office and each branch office<br />

located in an MSA/MD. See the suggested<br />

text for the poster in staff comment<br />

203.5(e)-1.<br />

Aggregate Tables Prepared<br />

by the FFIEC<br />

In addition <strong>to</strong> preparing individual<br />

disclosure statements, the FFIEC will<br />

combine the <strong>HMDA</strong> data submitted by<br />

all reporting institutions and produce<br />

aggregate tables for each MSA/MD.<br />

The FFIEC will also produce tables for<br />

each MSA/MD showing the lending<br />

patterns according <strong>to</strong> demographic<br />

characteristics provided by the Census<br />

Bureau, such as age of housing s<strong>to</strong>ck.<br />

The FFIEC will make available copies of<br />

the individual disclosure statements,<br />

MSA/MD aggregate tables, and other<br />

<strong>HMDA</strong> data products on the FFIEC web<br />

site, www.<strong>ffiec</strong>.gov/hmda.<br />

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