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In trying to determine whether we need to report HMDA data for 2017, we pass the first 4 criteria. However, I have hit a trouble spot with the 5th criteria for loans reported in the preceding two years. In 2015 we only had 22, and in 2016 we had 27, which seems to exempt us. However, we have a wholly owned subsidiary Mortgage Company and they file a separate LAR from the bank. Obviously they exceeded the 25 home purchase loans minimum for both years. Since we file separately, is the bank still exempt from filing or does our ownership of the mortgage company come into play? Scratching my head…..
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Your financial institution and your subsidiary mortgage company would determine coverage independently.
Your financial institution will follow the coverage rules under Reg C, 1003.2, for a bank, savings association, or credit union.The subsidiary would follow the coverage rules for a “for-profit mortgage lending institution” in Reg C under 1003.2.
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