Note: If the answer to question 6 is No, the merged institution does not have to report transactions that occurred during the year of the merger.
In the event that a revealing organization combined which have a non-revealing place, additionally the revealing business is the surviving business, towards seasons of merger, study collection is needed on the reporting institution’s purchases; investigation collection are optional on transactions addressed from inside the offices of this new in the past exempt low-revealing organization.
In the event that a reporting place merged that have a non-revealing institution, and the low-revealing facilities is the enduring place, otherwise a unique facilities is formed, towards the seasons of your merger, data range is required on reporting institution to possess purchases one to happened prior to the merger; research collection was elective having purchases that occurred following merger date.
In the event the each other organizations was indeed HMDA journalists, studies collection becomes necessary for the entire season of your own merger. The latest matched organization can get file either a beneficial consolidated submitting otherwise independent submissions.
Footnotes
Studies areas indicating whether or not ethnicity otherwise race recommendations is actually collected with the the foundation out of visual observance otherwise surname (FIG Data Career Amounts 30, thirty two, 49, and you may 50) aren’t utilized in any study class enumerated in the section 10 and tend to be handled since the personal investigation areas having reason for these types of recommendations.
Credit unions which aren’t federally insured was at the mercy of HMDA only when they replied Yes to questions step one, dos, 3, and you can 4 and at the very least one of many money at issue 3 is covered, protected, or supplemented because of the a national institution otherwise was designed because of the credit relationship offered to Fannie mae otherwise Freddie Mac. 1003.2(g)(1)(iv).
- The acquisition from closed-avoid mortgages or open-stop lines of credit as an element of good merger or acquisition, or within the purchase of all the property and you will obligations from a branch office because outlined within the 1003.2(c), 1003.3(c)(6);
Exchange Analysis
Charts illustrating brand new twenty-two data products maybe not protected by the fresh new partial exemptions additionally the twenty six analysis things included in new partial exemptions can be found in Appendix F out of A guide to HMDA Reporting: Getting hired Best!.
- HMDA purchase review should be divided in to several stages. Both degree test getting mistakes simply within the personal research fields you to definitely are chosen to have feedback due to the fact offered a lot more than within the paragraph 4. In Phase step one, examiners comment only a great subset of one’s test (Initially Sample). The size of the initial Test is based on the size of borrowing from the bank union’s HMDA LAR, as found from inside the column B of your own HMDA table. Should your level of mistakes understood throughout the First Test falls underneath the Initially Sample Tolerance within the line C of HMDA desk for every data industry analyzed, don’t test comment is necessary and the examiners get finish the transaction investigations. In case your amount of mistakes in virtually any research community reviewed means or is higher than the original Shot Threshold inside line C of HMDA dining table, examiners is to move on to Stage dos and you may feedback with the rest of the complete Attempt. In the Phase dos, examiners need comment the analysis industries that had no less than one problems in the First Decide to try and you can ple research industries examined and you will receive getting zero errors for the Phase 1.
- The latest Battle off Candidate or Debtor investigation field category: composed of 7 FIG areas with information on a keen applicant’s or borrower’s battle (FIG Research Job Amounts 33-40); and
Note: If all of the answers to questions 1, 2, 3, and 4 are “Yes,” the credit union is subject to HMDA in the current year and the remainder of the checklist should be completed (unless exempt by virtue of similar state law).