Q: § __.22(a)(1) – 1: If a large retail institution is not required to collect and report home mortgage data under the HMDA, will the Agencies still evaluate the institution’s home mortgage lending performance?
A: Yes. The Agencies will sample the institution’s home mortgage loan files in order to assess its performance under the lending test criteria.
This Interagency Q&A, and others, was released in July 2016.
The 2016 Q&As consolidates and supersedes all previously published “Interagency Questions and Answers Regarding Community Reinvestment,” and were noted as being effective immediately. They may be found here: http://www.ffiec.gov/cra/qnadoc.htm