§__.22(a)(1) – 1
Q: If a large retail institution is not required to collect and report home mortgage data under the HMDA, will the Agencies still evaluate the institution’s home mortgage lending performance?
A1. Yes. The Agencies will sample the institution’s home mortgage loan files in order to assess its performance under the lending test criteria.
Source: Interagency Questions & Answers Regarding Community Reinvestment | July 2016