Under the new regulation, the property address along with the state, county, and census tract data must be reported as part of your HMDA information. These data points must be reported if the property is located in an MSA or metropolitan division where the institution has a home or branch office. They should also be reported if the institution is a bank or savings association and they are required to report HMDA data on small businesses, small farms, and community development lending under the Community Reinvestment Act. The census tract has an additional reporting requirement as it is only reported if the property is located in a county with a population of 30,000 or more.
In order to determine which property data to report, the institution must look at which property is securing (or was proposed to secure) the loan. In the case where more than one property secures the loan, the institution should report the information for only one of the properties. If the property securing the loan is a single multifamily dwelling that has more than address, then just one of the addresses should be reported by the institution. In the instance where the property securing the loan is not known or the location for a manufactured home has not been identified, then the data point for the property address should be entered as being not applicable.
The majority of these data points can be determined by looking at the loan application; however, the county and census tract must be reported in numerical form. In order to determine what these values should be, the institution can enter the property address at: https://geomap.ffiec.gov
For more information on HMDA regulations, 2018 data point changes or our HMDA compliance services, please call Rhonda Wannemuehler or Betsy Reynolds at 855-734-7655.