Mortgage lenders might find themselves packaging and shipping their HMDA data about 30 days earlier than theyre used to if the Federal Reserve Board has its way, but some lender trade groups are expressing apprehension about any such move. The Fed proposed changes to Regulation C, the Home Mortgage Disclosure Act, including a provision that would mandate lenders to submit HMDA data for the year to their supervisory agencies by Feb. 1, instead of by the previous March 1 deadline. The rule would also require HMDA data to be turned in on computer tape or disk-ette. The board said it was proposing the change because statutory amendments to HMDA enacted in 1992 require HMDA reports for calendar year 1994 be available for the public by July 1 of the following year, and aggregate tables be available at central depositories by Sept. 1. To meet this timetable it will be necessary for the agencies to begin processing the raw data by Feb. 1, the Fed said in its June 7 notice. Comments are due to the Fed by Aug. 10. But while the Fed is focused on meeting deadlines, some industry lobbyists believe the rule could be oppressive to lenders. The proposal could be problematic, said Diane Casey, regulatory counsel with the Independent Bankers Association of America. Casey said the deadline could prove burdensome because lenders are already required to submit a large number of reports at the start of the year. Many larger banks have outsourc-ing agents that handle their geocoding responsibilities, said Sonia Barbara, a spokeswoman with the American Bankers Association. Barbara said the rule could be onerous to banks because they are locked into the March 1 deadline with their geocoding vendors, and might not be able to easily renegotiate the timing of the reports. Casey said the rule that all data be submitted on either tape or diskette could also present a problem. Technology is your friend when you have the technology, she said. Many of the smaller lenders arent computerized yet, so it might be a burden for them, too. The Fed is also soliciting comments regarding a proposed change to the definition of home improvement loan. The alteration would make the way an institution classifies a loan irrelevant to its treatment for HMDA purposes. As written, it is intended to ease the regulatory burden on lenders by not requiring them to report a loan as a home improvement loan on their HMDA-Loan/Application Register if the institution did not record the loan as such for other purposes. But the Fed said a number of institutions have expressed a desire to use those loans in their reports, but because these loans are not classified in the institutions records as home improvement loans, it has presented an obstruction to do so.

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