HMDA-LAR Submissions Due March 1

Blog posted by John Zasada

Here’s a friendly reminder: Credit unions that are required to report Home Mortgage Disclosure Act Loan Application Register (HMDA-LAR) information, your HMDA-LAR must be filed prior to March 1. Occasionally a credit union does not realize it is required to report HMDA data. Who is required to file a HMDA-LAR? You are—if you answer yes to the following questions:

• Is the depository institution a bank, credit union, or savings association?
• Did the assets of the institution total more than $40 million on the preceding December 31?
• Did the institution have a home or branch office in a metropolitan statistical area or metropolitan division (MSA/MD) on the preceding December 31?
• In the preceding calendar year, did the institution originate at least one home loan or refinancing of a home loan secured by a first lien on a one-to-four-family dwelling?
• Is the institution federally insured or regulated; or was the mortgage loan insured; guaranteed, or supplemented by a federal agency; or was the loan intended for sale to the Federal National Mortgage Association (FNMA) or Federal Home Loan Mortgage Corporation (FHLMC)?

Fair lending is getting a lot of attention from regulators. Regulators depend on accurate HMDA information as they conduct fair lending reviews. Consequently, regulators penalize financial institutions for inaccurate HMDA information. Last year about 60 banks were penalized by the FDIC for HMDA violations.

We see some of the same types of violations at credit unions. In the current regulatory environment, we cannot emphasize enough the importance of accurate HMDA reporting.