Lenders Covered by HMDA Data Reporting Requirements

Both depository institutions – such as banks, savings and loan associations, and credit unions – and nondepository institutions – including mortgage and consumer finance companies – are required to report HMDA data if they meet the regulatory criteria for coverage. These criteria are found in section 203.2(e) of the Federal Reserve Board’s Regulation C. Generally, the determination of HMDA coverage depends on:

• The lender’s asset size. For example, an institution is subject to HMDA reporting requirements if it has assets of $34 million or more, as of December 31, 2004. The Federal Reserve Board adjusts the coverage threshold from year to year to reflect changes in the consumer price index for urban wage earners and clerical workers. For a nondepository institution, total assets must exceed $10 million, as of December 31 of the preceding year, counting the assets of any parent corporation;
• Whether the lender has an office in a metropolitan statistical area; and
• The extent of the lender’s housing-related lending activity.

In 2004, 8,121 lenders reported HMDA data for 2003. The number of national banks that reported HMDA data for 2003 totaled 1,020. For more information about the specific coverage criteria for institutions under the HMDA regulations, go to http://www.ffiec.gov/hmda/pdf/2004guide.pdf.