that of an area containing a large population nucleus and adjacent communities that have a high degree of integration with that nucleus. The concept of a micropolitan statistical area closely parallels that of the metropolitan statistical area, but a micropolitan statistical area features a smaller nucleus. The purpose of these statistical areas is unchanged from when metropolitan areas were first delineated: The classification provides a nationally consistent set of delineations for collecting, tabulating and publishing federal statistics for geographic areas. The new delineations are found in OMB Bulletin 23-01 by scanning the QR code. https://www.whitehouse.gov/wp-content/ uploads/2023/07/OMB-Bulletin-23-01.pdf 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 closed-end 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). MONTANA MSA CHANGES OMB made some significant MSA changes that impact banks and thrifts in Montana, and their compliance with HMDA requirements. Only one existing MSA was unchanged — Great Falls MSA. Changes were made to the other two existing MSAs, and two new MSAs were designated as follows: • Billings MSA — Golden Valley County dropped from MSA; Stillwater County added. • Missoula MSA — Mineral County added. • Bozeman MSA — New MSA comprised of Gallatin County. • Helena MSA — New MSA comprised of Broadwater, Jefferson, and Lewis and Clark counties. All the details of the new Montana geographic delineations can be found in the OMB Bulletin mentioned above. The list of MSAs and micropolitan statistical areas by state is in List 6 (with Montana on pages 163-164) 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 for 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 two new MSAs or in Mineral or Stillwater counties, and in no other MSA counties, had to begin collecting HMDA data on Jan. 1, 2024, and have to make their first reports of that data by March 1, 2025. • Banks and thrifts whose offices in Golden Valley County have made them subject to HMDA reporting (i.e., no offices in other MSA counties) 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. Community Banker 21
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