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A community bank with $500 million in assets originated 75 home purchase loans, 15 refinance loans, and 10 home improvement loans secured by dwellings last year. What is their HMDA reporting obligation?

Correct Answer

B) They must report all 100 loans as they exceed the 25-loan threshold

Under Regulation C, institutions with assets over $48 million that originated at least 25 covered loans in each of the two preceding years must report HMDA data. All covered loans (purchase, refinance, and home improvement secured by dwellings) must be reported.

Answer Options
A
They are exempt from HMDA reporting due to low loan volume
B
They must report all 100 loans as they exceed the 25-loan threshold
C
They must report only if they have a branch in an MSA
D
They must report only the purchase loans since they exceed 75 loans

Why This Is the Correct Answer

Under Regulation C, institutions with assets over $48 million that originated at least 25 covered loans in each of the two preceding years must report HMDA data. All covered loans (purchase, refinance, and home improvement secured by dwellings) must be reported.

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