To: All Member Banks and Others Concerned in the Third Federal Reserve District

Attention: Chief Executive Officer and Chief Compliance Officer

Subject: HOME MORTGAGE DISCLOSURE; REGULATION C: FINAL RULE AND STAFF COMMENTARY

Summary:

The Board of Governors of the Federal Reserve System has published its annual notice of the asset-size exemption threshold for depository institutions under Regulation C, which implements the Home Mortgage Disclosure Act (HMDA).

The asset-size exemption for depository institutions will increase $1 million to a level of $34 million based on the annual percentage change in the Consumer Price Index for Urban Wage Earners and Clerical Workers for the 12-month period ending in November 2004. As a result, depository institutions with assets of $34 million or less as of December 31, 2004, are exempt from data collection in 2005. An institution’s exemption from collecting data in 2005 does not affect its responsibility to report the data it was required to collect in 2004.

HMDA and the Board’s Regulation C require most depository institutions and certain for-profit, nondepository institutions to collect, report, and disclose data about applications for, and originations and purchases of, home mortgage loans, home improvement loans, and refinancings. Data reported include the type, purpose, and amount of the loan; the race, ethnicity, sex, and income of the loan applicant; and the location of the property. The purposes of HMDA include helping to determine whether financial institutions are serving the housing needs of their communities and assisting in fair lending enforcement.

The Federal Register notice, published December 27, 2004, is available here (14 KB, 3 pages).

Date: The adjustment is effective January 1, 2005.

For Further Information: John C. Wood or Kathleen C. Ryan, Counsels, or Dan S. Sokolov, Senior Attorney, Division of Consumer and Community Affairs, at (202) 452-3667; for users of Telecommunications Device for the Deaf (TDD) only, contact (202) 263-4869.