+--------+---+-----------------------+--------+-----------------------+---+
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|        | 4 |                       |        |                       |   |
|        | - |                       |        |                       |   |
|        | 1 |                       |        |                       |   |
|        | 5 |                       |        |                       |   |
+--------+---+-----------------------+--------+-----------------------+---+
|        | * |                       |        |                       |   |
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+--------+---+-----------------------+--------+-----------------------+---+
| ## Com |   |                       |        |                       |   |
| ptroll |   |                       |        |                       |   |
| er of  |   |                       |        |                       |   |
| the Cu |   |                       |        |                       |   |
| rrency |   |                       |        |                       |   |
|        |   |                       |        |                       |   |
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| tional |   |                       |        |                       |   |
| >      |   |                       |        |                       |   |
|  Banks |   |                       |        |                       |   |
+--------+---+-----------------------+--------+-----------------------+---+
| ## Su  |   | ## Home Mo            | ##     | ## Updated E          |   |
| bject: |   | rtgage Disclosure Act | Descri | xamination Procedures |   |
|        |   |                       | ption: |                       |   |
+--------+---+-----------------------+--------+-----------------------+---+

**TO:** Chief Executive Officers and Compliance Officers of All National
Banks, Department and Division Heads, and All Examining Personnel

The Board of Governors of the Federal Reserve System substantially
amended its Regulation C, which implements the Home Mortgage Disclosure
Act (HMDA) in early 2003. The changes became effective on January 1,
2004. The Federal Financial Institutions Examination Council's Task
Force on Consumer Compliance approved the attached updated interagency
HMDA examination procedures in December 2003.

The major regulatory changes relate to additional information
requirements lenders must include on their HMDA Loan Application
Register. Lenders are required to:

-   Collect applicant ethnicity and race information using a new format
    and revised descriptive codes.

-   Record borrower requests for preapprovals that meet the Regulation C
    definition.

-   Report the rate spread between the loan Annual Percentage Rate and
    the yield on comparable Treasury securities if the spread is equal
    to or greater than 3 percentage points for first-lien loans, or
    equal to or greater than 5 percentage points for subordinate-lien
    loans.

-   Report whether the loan is subject to the Home Ownership and Equity
    Protection Act (HOEPA), 15 USC 1639.

-   Report whether a loan or application involves a manufactured home.

-   Report, for originated loans and applications, but not purchased
    loans, whether a loan is or would be 1) secured by a first lien on a
    dwelling; 2) secured by a subordinate lien on a dwelling; or 3) not
    secured by a lien on a dwelling.

The Comptroller of the Currency plans to incorporate these procedures in
an update to the *Comptroller's Handbook* series. Until the revised
handbook is issued, examiners will use the attached procedures.
Questions about the HMDA and these examination procedures may be
directed to your supervisory office or the Compliance Department at
(202) 874-4428.

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Ann F. Jaedicke

Deputy Comptroller for Compliance

Attachment: [Examination
Procedures](http://www.occ.treas.gov/ftp/bulletin/2004-15a.pdf)