HMDA Coverage Regulation C covers any “financial institution,” as defined by the regulation and its underlying HMDA statute. “Financial institution” means, in part, a bank, savings association or credit union that: • On the preceding Dec. 31, had assets in excess of the asset threshold established and published annually by the CFPB for coverage by HMDA, based on the year-to-year change in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers, not seasonally adjusted, for each 12-month period ending in November, rounded to the nearest million — $56 million for 2024 HMDA coverage. • On the preceding Dec. 31, had a home or branch office in a Metropolitan Statistical Area (MSA). [Micropolitan Statistical Areas have no HMDA impact.] • In the preceding calendar year, originated at least one home purchase loan (excluding temporary financing such as a construction loan) or refinancing of a home purchase loan, secured by a first lien on a one- to four-family dwelling. • Meets one or more of the following two criteria: is federally insured or regulated; or the mortgage loan referred to in the previous bullet was insured, guaranteed or supplemented by a federal agency or was intended for sale to Fannie Mae or Freddie Mac. • Meets at least one of the following criteria in each of the two preceding calendar years: originated at least 25 closedend mortgage loans that are not excluded by §1003.3(c)(1) through (10) or (c)(13), or originated at least 200 open-end lines of credit that are not excluded by the cited section of Regulation C. There are also similar qualification criteria for for-profit mortgage lenders that are not banks, thrifts or credit unions, which we will not detail here. The qualification criterion impacted by OMB’s action is the geographic one, the second bullet above. If a financial institution that otherwise meets HMDA coverage criteria has an office in an MSA on Dec. 31, then it is covered by HMDA for the following year. For many lenders, determining HMDA coverage is a one-time exercise (other than those who are right around the asset-size threshold). Kansas MSA Changes OMB made some significant MSA changes that impact banks and thrifts in Kansas and their compliance with HMDA requirements. Four existing MSAs were unchanged — Kansas City, Lawrence, St. Joseph and Topeka MSA. Changes were made to the other two existing MSAs and one out-of-state MSA had a Kansas county added, as follows: • Joplin MSA — Cherokee County (Kansas) added. • Manhattan MSA — Geary County added. • Wichita MSA — Kingman County added. All the details of the new Kansas geographic delineations can be found in the OMB Bulletin mentioned previously. The list of MSAs and micropolitan statistical areas by state is in List 6 (with Kansas on pages 157-158) of the OMB Bulletin, while five additional lists in the bulletin give other breakdowns of the geographic delineations, including the counties included in each. HMDA Impact In 2023, there was no impact on HMDA reporting because the new MSA delineations were not in effect on Dec. 31, 2022. However, they were in effect Dec. 31, 2023, which has the following impacts: • Banks and thrifts with offices in the newly included counties — Cherokee, Geary, and Kingman — and in no other MSA counties now have had to begin collecting HMDA data by Jan. 1, 2024, and must make their first reports of that data by March 1, 2025. • Unlike 10 years ago, there are no banks and thrifts whose offices in Kansas counties have made them subject to HMDA reporting (i.e., no offices in other MSA counties) that will no longer have to collect HMDA data beginning in 2024. (Note that such banks would still be obligated to report their 2023 HMDA data by March 1, 2024.) If your institution has an office in any of the counties affected by the MSA changes, be sure to review how this action affects your HMDA compliance beginning in 2024. There are changes that arrived with the new year of 2024 to Home Mortgage Disclosure Act (HMDA) compliance for banks and thrifts in many areas. 11 In Touch
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