FRB FAQs-We have 20 bank locations; however, only two locations have a formal preapproval program as defined by Regulation C. Is our bank considered to have a preapproval program for all locations?

Compliance > Regulation C - HMDA > FRB FAQs

Q:  We have 20 bank locations; however, only two locations have a formal preapproval program as defined by Regulation C. Is our bank considered to have a preapproval program for all locations, or is it acceptable for the 18 locations without a preapproval program to use “3” (NA) when reporting the preapproval code on home purchase loans?

A:  Under §203.4(a)(4), an institution must report whether an application is a request for preapproval. The HMDA instructions explain that an institution should enter code 3 (NA) if an institution does not have a covered preapproval program. An institution should report code 2 if the institution has a covered preapproval program but the applicant does not request a preapproval.

If applications submitted at the 18 branches will not or could not be evaluated under a covered preapproval program, these applications could be reported as code 3 or “NA” because the bank does not have a program at those offices for issuing preapprovals, as defined under Regulation C.
 

This can be found in - HMDA FAQ#11 of the FAQs.  The Federal Reserve Board FAQs can be found at: https://consumercomplianceoutlook.org/2011/second-quarter/hmda-and-cra-data-reporting/

 

 

Add Feedback