Revised HMDA Regulation Disclosure Requirement

These newsletters are intended to help you with regulatory compliance. GeoDataVision issues these advisories periodically.

Revised HMDA Regulation Disclosure Requirement

So you've just finished filing your 2005 HMDA LAR and now it's time to relax. Right? Well not quite! Until now almost everyone has been focused on their HMDA LAR filing and the significant changes to the LAR. New fields were added and old fields were modified multiplying the potential for error exponentially. Not only did you have to record entirely new information such as the "rate spread" and "lien status" fields, but old codes pertaining to race, etc., were changed. So, many people breathed a collective sigh of relief when they filed their LAR's. However, the revised regulation does impose another requirement pertaining to the LAR that has been overlooked by many - the disclosure of a modified LAR that must be made available to the public no later than March 31 for requests received before March 1, and within 30 days of receipt of a request thereafter.

Institutions must make their LAR, modified to protect the privacy of applicants and borrowers, available to the public in electronic or printed form. Three fields must be deleted: the application or loan number, the date the application was received and the data the action was taken. No other deletions to the LAR are permitted by Reg C. The regulation does not require changes to the format or order of the data, although institutions are encouraged to make the data available in census tract order if possible. The modified LAR must continue to be made available to the public for three years thereafter. We suggest that, rather than wait for a request for the modified LAR (that can be received for up to 3 years later), the modified LAR be created and exported in electronic format as soon as possible and stored in an appropriately designated file. This procedure will provide several advantages. First, it is better to prepare the data while you have it fresh in your mind rather than waiting for a request that may come in years later. Second, having the information already prepared and waiting for any future requests removes any pressure to produce the data at times when you may be under other stresses (such as preparing the LAR in subsequent years). If you subsequently file a corrected LAR, it should be SOP to change the modified LAR available for public inspection.

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