Implication of New Metropolitan Statistical Areas on HMDA Reporting
December 23, 2003
Circular No. 11563

To All Depository Institutions and Others Concerned in the Second Federal Reserve District:

The Office of Management and Budget (OMB) adopted final standards for 2000 Census Metropolitan and Micropolitan Statistical Areas and on June 6, 2003 issued a list of these areas. There are 49 new Metropolitan Statistical Areas, for a total of 370. There are also extensive revisions to existing Metropolitan Statistical Areas. In some cases, Metropolitan Statistical Areas will be divided into Metropolitan Divisions.

The new list also contains 565 new Micropolitan Statistical Areas. However, Micropolitan Statistical Areas will NOT be used for HMDA reporting purposes. In addition, the new list contains 116 Combined Statistical Areas, which consist of combinations of two or more Metropolitan and/or Micropolitan Statistical Areas. Combined Statistical Areas will also NOT be used in HMDA reporting.

Beginning with the reporting of calendar year 2004 HMDA data, the revised and new Metropolitan Statistical Areas or Metropolitan Divisions (where appropriate) will be used to help identify the geographic information about the property location. The Metropolitan Area (MA) reference used in 2003 HMDA data will be changed to Metropolitan Statistical Area/Metropolitan Division (MSA/MD) in 2004.

The June 2003 changes in Metropolitan Statistical Area (MSA) boundaries and terminology have raised questions from HMDA reporters. For your convenience, here are answers to the most common questions:

  • The new MSAs can be found in the OMB Bulletin No. 03-04, Attachment, List 2.
    OMB Bulletin No. 03-04, Attachment, List 2 OFFSITE PDF
    141 pages / 659 kb
  • A five-digit MSA code from the new list of MSAs is to be used for any application that sees final action in 2004. Use the five-digit code for Metropolitan Divisions when available.
  • A four-digit MSA code from the old list of MSAs is to be used for any application that sees final action in 2003.

If an institution has become a HMDA reporter for the first time because of changes in MSA boundaries, they should begin collecting data with applications received on January 1, 2004. Data should not be collected on applications received in 2003 even if they see final action in 2004. This is a limited exception, only for new reporters, to the general rule that the loan/application register (LAR) must include all transactions that see final action in the year of the LAR.

Another resource to further clarify this and other changes to Regulation C effective January 1, 2004 is the Federal Reserve Bank of St. Louis' HMDA Regulation C Amendments Guide on the Internet. OFFSITE

Robert Gutierrez
Examining Officer
Legal and Compliance Risk Function