Previous Document IconPrevious Info Memo

Next Document IconNext Info MemoExam Manual Table of Contents IconList of Info Memos

Informational Memorandum
Subject:Regulation C, Home Mortgage Disclosure Act
Date of Memorandum:02/23/2004
Expiration Date:
Signed By:Smith, Roland
FCA Contact Person:Holland, Tom
Contact Phone:703-883-4484
List of Attachments:Federal Reserve Board Final Rule
68 FR 74829 (Dec. 29


February 23, 2004

To: The Chief Executive Officer
All Farm Credit System Institutions

From: Roland E. Smith, Director
Office of Examination

Subject: Regulation C, Home Mortgage Disclosure Act

The Board of Governors of the Federal Reserve System (Federal Reserve Board) recently revised Regulation C, 12 CFR Part 203. the implementing regulation for the Home Mortgage Disclosure Act (HMDA), 12 U.S.C. 2801 et seq. as well as the staff commentary interpreting the regulation. 68 FR 74829 (Dec. 29, 2003). The revisions reflect changes in the Standards for Defining Metropolitan and Micropolitan Statistical Areas published by the U.S. Office of Management and Budget (OMB) in December 2000 (the 2000 Standards). 65 FR 82228 (Dec. 27, 2000). The effective date of the revisions was January 1, 2004.

Under HMDA, most financial institutions, including Farm Credit System institutions, that are located in Metropolitan Statistical Areas A lending institution is deemed to be located in an MSA if: (a) its home office or a branch office that takes applications for home purchases or home improvement loans is in that MSA; or (b) in the preceding calendar year, it received applications for, originated, or purchased five or more home purchase or home improvement loans on property located in that MSA. (MSAs) and that satisfy certain other criteria related to asset size and volume of home purchase loan originations are required to collect, submit to the appropriate federal supervisory agency, and make available to the public specified data about their housing-related lending activity. Until its recent revision, Regulation C had incorporated OMB definitions of a MSA and a Primary Metropolitan Statistical Area (PMSA) for determining coverage under HMDA, reporting property location, providing disclosures and reports of lending activity, and posting notices about the availability of HMDA data.

The 2000 Standards published by OMB take a new approach. Although they retain the concept of an MSA, they no longer designate areas as PMSAs. Instead, they divide large MSAs (with populations of at least 2.5 million) into Metropolitan Divisions. Each Metropolitan Division consists of one or more counties that represent an employment center within an MSA. Therefore, the Federal Reserve Board revised Regulation C to refer to MSAs and Metropolitan Divisions rather than MSAs and PMSAs. In June 2003, OMB released a list of MSAs and Metropolitan Divisions, based on the application of the 2000 Standards to data from the 2000 Census. OMB Bulletin No. 03-04 (June 6, 2003) (available at ).

A copy of the Federal Reserve Board's final rule is attached. Extensive guidance on complying with the revised Regulation C can be found on the HMDA page of the Web site of the Federal Financial Institutions Examination Council (FFIEC):

If you have any questions regarding the revisions to Regulation C and staff commentary, please call Thomas J. Holland, Director, Special Examination and Supervision Division, Office of Examination, at (703) 883-4483, or write to him on the Internet at e-mail address

Federal Reserve Board Final Rule, 68 FR 74829 (Dec. 29, 2003)