Interagency Q&A .42(b)(3) – 1: Must institutions that are not required to collect home mortgage loan data by the HMDA collect home mortgage loan data for purposes of the CRA?

Compliance > Regulation BB - CRA
Q:  § __.42(b)(3) – 1: Must institutions that are not required to collect home mortgage loan data by the HMDA collect home mortgage loan data for purposes of the CRA?
 
A:  No.  If an institution is not required to collect home mortgage loan data by the HMDA, the institution need not collect home mortgage loan data under the CRA.  Examiners will sample these loans to evaluate the institution’s home mortgage lending.  If an institution wants to ensure that examiners consider all of its home mortgage loans, the institution may collect and maintain data on these loans.
 
 
 
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
 

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