A Guide to HMDA Reporting - ffiec

Data
Reporting
In General
The Loan/Application
Register (LAR)
HMDA requires covered institutions to
compile and disclose on a calendar-year
basis data about applications for, originations
of, and purchases of home purchase
loans, home improvement loans,
and refinancings. Information about each
application or loan, and about each
applicant or borrower, is reported on a
loan-by-loan, application-by-application
basis on a loan/application register (LAR,
or register). The LAR must be completed
in accordance with Regulation C (Appendices
A–C to this Guide) and the staff
commentary (Appendix D to this Guide).
Appendix A to Regulation C (Appendix
A to this Guide) prescribes the format of
the LAR, including the fields' names,
sizes, and order. An electronic copy of
the LAR is available at www.ffiec.gov/
hmda. You need not use the form that
appears in the appendix, but your layout
must follow its format. The regulation
does not prescribe the order in which the
loans appear on your register, and the
loans need not be grouped by type or
other variable.
A LAR for a given calendar year must
contain all reportable applications that
reached final action (e.g., origination of
a loan, denial of an application) in that
year, regardless in which year the application
was submitted. The LAR should
exclude applications that have not yet
reached a final action; those applications
should appear on the LAR for the calendar
year in which they reach final action.
Separate or Combined
Registers?
You may prefer to keep a separate register
for each of the different categories
of loans—or even separate registers
at different branches. Keep in mind,
however, that the application or loan
identifiers must be unique within your
institution. For example, if your report
contains data from several branch
offices, and each branch keeps its own
register, assign codes or series of numbers
to each branch to avoid duplication.
Send all the registers for your
institution to your processing agency in
a consolidated report or automated file
annually by March 1 following the calendar
year of the data. See page 25.
Quarterly updates. Regulation C
requires quarterly updates of the LAR.
A covered institution must record a
transaction on the LAR within thirty days
after the end of the calendar quarter in
which final action on the transaction is
taken (such as origination or purchase
of a loan, or denial of an application).
Your regulator may require you to
update the data more frequently than
Regulation C requires.
Practical Tips for Quarterly
Updates:
¢ If you use an outside servicer to
geocode property locations, make
appropriate arrangements to have
geocoding completed on a timely
basis.
¢ In some cases you may be able to
wait until the loan transaction is complete
to determine the census tract
number (for example, from the
appraisal report) and still meet the
quarterly updating requirement. But
keep in mind that census tract numbers
are also required for loan applications
that are denied or withdrawn.
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