HMDA REFERENCE GUIDE - Sterling Compliancesterlingcompliancellc.com/wp-content/uploads/2018/01/HMDA-REFERENCE-GUIDE.pdfHMDA Reference Guide IN THIS GUIDE The documents within this

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HMDA REFERENCE GUIDE

HMDA Reference Guide

IN THIS GUIDE The documents within this package were developed as we, and the industry, planned for implementation of expanded data collection and reporting requirements under the Home Mortgage Disclosure Act (HMDA). The documents were compiled into this guide, and combined with a summary of the guidance published by the CFPB to assist you in ongoing administration and compliance with HMDA requirements.

HMDA Data Reporting Breakdown

HMDA Key Fields

HMDA Procedures

HMDA Data Collection Checklist

HMDA Demographic Collection Form

HMDA: Multiple Purpose Loans

Reporting “NA” Reference Guide

Action Taken Reference Guide

HMDA: Common Q&A

CFPB HMDA Resources

DATA POINT DESCRIPTION STATUS REGULATORY REFERENCE

Legal Entity Identifier(LEI)

Identifier issued to the financial institution (FI) by a utilityendorsed by the Global LEI Foundation or LEI RegulatoryOversight Committee

MODIFIED 1003.4(a)(1)(i)(A)

Universal Loan Identifier(ULI)

Identifier assigned to identify and retrieve a loan or applicationthat contains the FI's LEI, an internally generated sequence ofcharacters and a check digit

MODIFIED1003.4(a)(1)(i)

Comments 4(a)(1)(i)-1 through 5 andAppendix C

Application Date Date the application was received or the date on the applicationform EXISTING 1003.4(a)(1)(ii)

Comments 4(a)(1)(ii)-1 through 3

Loan TypeIndicates whether the loan or application is insured by theFederal Housing Administration, guaranteed by the VeteransAdministration, Rural Housing Service or Farm Service Agency

EXISTING 1003.4(a)(2)Comment 4(a)(2)-1

Loan PurposeIndicates whether the transaction is for a home purchase, homeimprovement, refinancing, cash-out refinancing or anotherpurpose

MODIFIED 1003.4(a)(3)Comments 4(a)(3)-1 through 5

Preapproval Indicates whether the transaction involved a preapproval requestfor a home purchase loan under a preapproval program MODIFIED 1003.4(a)(4)

Comments 4(a)(4)-1 and 2

Construction Method Indicates whether the dwelling is site-built or a manufacturedhome MODIFIED 1003.4(a)(5)

Comments 4(a)(5)-1 through 3

Occupancy Type Indicates whether the property will be used as a principalresidence, second residence or investment property MODIFIED 1003.4(a)(6)


Loan Amount Amount of the loan or the amount for which the consumerapplied MODIFIED 1003.4(a)(7)


Action Taken Type of action taken on the loan, application or preapprovalrequest EXISTING

1003.4(a)(8)Comments 4(a)(8)(i)-1 through 14 and

4(a)(8)(ii)-1 through 6

Action Taken Date Date of action taken on the loan, application or preapprovalrequest EXISTING

1003.4(a)(8)Comments 4(a)(8)(i)-1 through 14 and

4(a)(8)(ii)-1 through 6

Property Address Address of the property securing the loan or proposed to securethe loan NEW

1003.4(a)(9)(i)Comments 4(a)(9)-1 through 5 and

4(a)(9)(i)-1 through 3

Property Location Location of the property securing the loan or proposed to securethe loan by state, county and census tract EXISTING

1003.4(a)(9)(ii)Comments 4(a)(9)-1 through 5,

4(a)(9)(ii)(B)-1 and 4(a)(9)(ii)(C)-1

Ethnicity, Race & SexApplicant's or borrower's ethnicity, race and sex. Also, indicateswhether this information was collected by visual observation orsurname

MODIFIED1003.4(a)(10)(i)

Comments 4(a)(10)(i)-1 and 2 andAppendix B

Age Applicant's or borrower's age NEW 1003.4(a)(10)(ii)Comments 4(a)(10)(ii)-1 through 5

Income

If credit decision is made = gross annual income relied on inmaking the credit decision.If credit decision is not made = gross annual income relied on inprocessing the application.

EXISTING 1003.4(1)(10)(iii)Comments 4(a)(10)(iii)-1 through 10

Type of Purchaser Type of entity that purchased the loan MODIFIED 1003.4(a)(11)Comments 4(a)(11)-1 through 10

Rate Spread Difference between the APR and average prime offer rate for acomparable transaction MODIFIED 1003.4(a)(12)


HOEPA Status Indicates whether the loan is a high-cost mortgage under theHome Ownership and Equity Protection Act EXISTING 1003.4(13)

Comment 4(a)(13)-1

Lien Status Indicates whether the lien is a first or subordinate lien MODIFIED 1003.4(a)(14)Comments 4(a)(14)-1 and 2

Credit Score Credit score(s) relied upon and the name and version of thecredit scoring model NEW 1003.4(a)(15)


Reason for Denial Reason(s) the application was denied MODIFIED 1003.4(a)(16)Comments 4(a)(16)-1 through 4

Total Loan Costs or TotalPoints & Fees Either total loan costs or total points and fees charged NEW

1003.4(a)(17)Comments 4(a)(17)(i)-1 through 3

and 4(a)(17)(ii)-1 through 2

HMDA | REPORTABLE DATA BREAKDOWN

DATA POINT DESCRIPTION STATUS REGULATORY REFERENCE

HMDA | REPORTABLE DATA BREAKDOWN

Origination Charges Total borrower-paid origination charges NEW 1003.4(a)(18)Comments 4(a)(18)-1 through 3

Discount Points Points paid to the creditor to reduce the interest rate NEW 1003.4(a)(19)Comments 4(a)(19)-1 through 3

Lender Credits Amount of lender credits NEW 1003.4(a)(20)Comments 4(a)(20)-1 through 3

Interest Rate Interest rate o the approved application or loan NEW 1003.4(a)(21)Comments 4(a)(21)-1 through 3

Prepayment Penalty Term Term in months of any prepayment penalty NEW 1003.4(a)(22)Comments 4(a)(22)-1 through 2

Debt-to-Income Ratio Ratio of the applicant's or borrower's total monthly debt to totalmonthly income relied on NEW 1003.4(a)(23)

Comments 4(a)(23)-1 through 7Combined Loan-to-ValueRatio

Ratio of the total amount of debt that is secured by the propertyto the value of the property that was relied on NEW 1003.4(a)(24)


Loan Term Number of months after which the legal obligation will mature orterminate NEW 1003.4(a)(25)


Introductory Rate Period Number of months until the first date the interest rate maychange NEW 1003.4(a)(26)


Non-Amortizing FeaturesIndicates whether the transaction involves a balloon payment,interest-only payments, negative amortization or ay other type ofnon-amortizing feature

NEW 1003.4(a)(27)Comment 4(a)(27)-1

Property Value Value of the property relied on that secures the loan NEW 1003.4(a)(28)Comments 4(a)(28)-1 through 4

Manufactured HomeSecured Property Type

Indicates whether the covered loan is secured by a manufacturedhome and land or a manufactured home with no land NEW 1003.4(a)(29)


Manufactured HomeLand Property Interest

Information about the applicant's or borrower's ownership orleasehold interest in the land where the manufactured home islocated

NEW 1003.4(a)(30)Comments 4(a)(30)-1 through 6

Total Units Number of individual dwelling units related to the property NEW 1003.4(31)Comments 4(a)(3)-1 through 4

Multifamily AffordableUnits

Number of individual dwelling units related to the property thatare income-restricted under federal, state or local affordablehousing programs

NEW 1003.4(a)(32)Comments 4(a)(32)-1 through 6

Application Channel Indicates whether the application was submitted directly to the FIand whether the obligation was initially payable to the FI NEW

1003.4(a)(33)Comments 4(a)(33)-1, 4(a)(33)(i)-1,

and 4(a)(33)(ii)-1 through 2Mortgage LoanOriginator NMLSRIdentifier

National Mortgage Licensing System Registry (NMLSR) identifierfor the MLO NEW 1003.4(a)(34)


Automated UnderwritingSystem

Name of the automated underwriting system used by the FI toevaluate the application and the result generated by that system NEW 1003.4(a)(35)

Comments 4(a)(35)-1 through 6Reverse Mortgage Indicates of whether the transaction is for a reverse mortgage NEW 1003.4(a)(36)

Open-End Line of Credit Indicates whether the transaction is for an open-end line of credit NEW 1003.4(a)(37)Comment 4(a)(37)-1

Business or CommercialPurpose

Indicates whether the transaction is primarily for a business orcommercial purpose NEW 1003.4(a)(38)

Comment 4(a)(38)-1

This guide summarizes the requirements under HMDA and Regulation C and has primarily been derived from the CFPB's Summary of Reportable Data chart. This guide isintended only for a quick reference and is not a substitute for the regulation or official commentary. It does not contain information about the submission process, nor does itaddress any of the exceptions that are found in the HMDA Rule.

S t e r l i n g C O M P L I A N C E , L L C 1 | P a g e

To evaluate financial institutions’ compliance with HMDA requirements, FRB, FDIC, and OCC

examination staffs will focus on the Designated Key HMDA Data Fields during transaction testing

pursuant to the HMDA for data collected on or after January 1, 20181. In certain circumstances,

however, consistent with the FFIEC guidelines, such examination staff may determine that it is

necessary to review additional HMDA data fields, as appropriate.

Field #

Data Field Name Data Point Name

3 Universal Loan Identifier (ULI) Universal Loan Identifier (ULI)

4 Application Date Application Date

5 Loan Type Loan Type

6 Loan Purpose Loan Purpose

9 Occupancy Type Occupancy Type

10 Loan Amount Loan Amount

11 Action Taken Action Taken

12 Action Taken Date Action Taken Date

18 Census Tract Property Location

19 Ethnicity of Applicant or Borrower: 1 Ethnicity

25 Ethnicity of Co-Applicant or Co-Borrower: 1 Ethnicity

33 Race of Applicant or Borrower: 1 Race

34 Race of Applicant or Borrower: 2 Race

41 Race of Co-Applicant or Co-Borrower: 1 Race

42 Race of Co-Applicant or Co-Borrower: 2 Race

51 Sex of Applicant or Borrower Sex

52 Sex of Co-Applicant or Co-Borrower Sex

55 Age of Applicant or Borrower Age

56 Age of Co-Applicant or Co-Borrower Age

57 Income Income

61 Lien Status Lien Status

62 Credit Score of Applicant or Borrower Credit Score

1 Each agency shall operate in accordance with its supervisory authority.

HMDA | DESIGNATED KEY FIELDS

S t e r l i n g C O M P L I A N C E , L L C 2 | P a g e

Field #

Data Field Name Data Point Name

63 Credit Score of Co-Applicant or Co-Borrower

Credit Score

75 Origination Charges Origination Charges

76 Discount Points Discount Points

77 Lender Credits Lender Credits

78 Interest Rate Interest Rate

80 Debt-to-Income Ratio Debt-to-Income Ratio

81 Combined Loan-To-Value Ratio Combined Loan-To-Value Ratio

82 Loan Term Loan Term

88 Property Value Property Value

89 Manufactured Home Secured Property Type Manufactured Home Secured Property Type

91 Total Units Total Units

102 Automated Underwriting System Result: 1 Automated Underwriting System

108 Reverse Mortgage Reverse Mortgage

109 Open-End Line of Credit Open-End Line of Credit

110 Business or Commercial Purpose Business or Commercial Purpose

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DATA COLLECTION

The following procedures are designed to guide you through the data collection process under the Home

Mortgage Disclosure Act (HMDA) for applications received on or after January 1, 2018. HMDA Loan

Application Register (LAR) data fields and their corresponding source documents have been outlined. It is

critical that the source of the data for every application is consistent. The source documents listed as

suggested and possible examples; your internal processes and procedures may include additional source

documents not listed here.

Please note that these procedures address the data collection and recording process based on the CFPB’s Filing

Instruction Guide. You should document additional procedures to capture, at a minimum: How the data is actually

captured within your organization (e.g. loan officer gathering of data, HMDA worksheet, system forms, etc.); the

individual(s) responsible for entering the data into your core or HMDA software; the processes you have in place to

test the data; and, your submission process (e.g. how LAR data is submitted electronically).

Data Point Source Document Procedure

Legal Entity Identifier

(LEI)

▪ LEI Registration ▪ Call Report

Enter your institution’s LEI. Width specification: 20 characters

Universal Loan

Identifier (ULI)

Internal methodology Enter the ULI for the transaction based on your internal methodology

Width specification: 45 characters

Once the ULI is assigned, it stays with the loan.

If you purchase a covered loan, you must use the ULI that was assigned by the institution that originated the loan.

If no ULI was assigned by the originating institution, you assign a ULI, record and submit the transaction on your LAR.

A situation like this may occur if a loan was originated prior to 1/1/2018.

Application Date ▪ Uniform Residential Loan Application (1003)

▪ Home Equity Application, if other than URLA

▪ Commercial Loan Application

▪ Commercial Loan Write-up

Report the date the application was received. Every 1003 and Home Equity application should have a received date clearly indicated by the loan officer. The application should also indicate whether it was taken by phone, in person or by fax, mail or email.

Commercial loans secured by a dwelling for the purposes of purchasing, improving or refinancing the dwelling must have a clearly defined application date notated in the file.

Example: 20180721

HMDA PROCEDURES

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For an application that was not submitted directly to you, you may report the date the application was received by the party that originally received the application, the date you received the application or the date shown on the application form.

For a request to reinstate or reconsider an earlier application as a new transaction, report the date of the request as the application date. Otherwise, report the original application date.

Loan Type Application 1. Conventional Not insured or guaranteed by FHA, VA, RHS or FSA

2. Federal Housing Administration Insured (FHA) 3. Veterans Affairs Guaranteed (VA) 4. USDA Rural Housing Service or Farm Service Agency

Guaranteed (RHS or FSA)

Loan Purpose ▪ Application ▪ Commercial Loan

Write-up

1. Home Purchase 2. Home Improvement

31. Refinancing

32. Cash-out Refinancing

4. Other Purpose

5. Not Applicable

Documentation of loan purpose within application or commercial loan write-up should be SPECIFIC.

Preapproval File documentation of preapproval request

Formal preapproval request if applicable

1. Preapproval requested 2. Preapproval not requested

Be sure your processes are well-defined between pre-qualifications and preapprovals. Pre-qualifications are not reportable.

Construction Method Appraisal or evaluation 1. Site-built 2. Manufactured Home

Modular homes and prefabricated components are reported as site-built regardless of whether they are on-frame or off-frame modular homes.

For a multi-family dwelling, report the construction method as site-built unless the multifamily dwelling is in a manufactured home community.

Occupancy Type Application or credit write-up

1. Principal residence 2. Second residence 3. Investment property

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For HMDA reporting purposes, an applicant or borrower can have only 1 principal residence at a time. If an applicant or borrower buys or builds a new dwelling that will become the applicant’s principal residence within a year or upon the completion of construction, the new dwelling is considered the principal residence for purpose of applying this definition to a particular transaction.

A second residence is one in which the applicant will occupy the dwelling for a portion of the year and is not the applicant’s primary dwelling.

An investment property is any property that is not the applicant’s primary or secondary residence.

Loan Amount Note Enter the loan amount.

Example: 110500 or 100500.00

The field is no longer rounded

For a closed-end mortgage, other than a purchased loan, an assumption or a reverse mortgage, the amount to be repaid as disclosed on the Promissory Note is the loan amount.

For purchased closed-end mortgages or an assumption for a closed-end mortgage, the unpaid principal balance at the time of the purchase or assumption is the loan amount.

For an open-end line of credit, other than a reverse mortgage open-end line of credit, the amount of credit available to the applicant is the loan amount.

For a reverse mortgage, the initial principal limit is the loan amount.

Counteroffer: If an applicant accepts a counteroffer for an amount different from the amount for which he or she initially applied, report the loan amount granted. If counteroffer is not accepted, report the amount originally requested.

Multiple-Purpose Loan: Report the entire amount of the loan even if only a portion of the proceeds are being used for home purchase, home improvement or refinancing purposes.

Refinancing: Report the amount of credit extended under the new debt obligation.

Action Taken File documentation 1. Loan originated

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Note

Adverse Action Notice

2. Application approved but not accepted 3. Application denied 4. Application withdrawn by applicant 5. File closed for incompleteness 6. Purchased loan 7. Preapproval request denied 8. Preapproval request approved but not accepted

If you purchased the loan after closing or account opening and you did not make the credit decision on the application prior to closing or account opening, report the action taken as Code 6 – Purchased Loan.

If you are repurchasing a loan from the entity to which you sold it and you made the credit decision before closing or account opening, report the action taken as Code 6 – Purchased Loan.

Approved Not Accepted: Use this code when you made a credit decision approving the application before closing or account opening, subject only to outstanding conditions that are customary commitment or closing conditions, but the applicant fails to respond to the approval or it was otherwise not consummated.

Withdrawn: Use this code only when the applicant expressly withdraws the application before you make a credit decision or before the file is closed for incompleteness.

Closed for Incompleteness: Use this code when you sent a written notice of incompleteness to which the applicant did not respond within the specified period of time. If you provide a notice of adverse action on the basis of incompleteness, you may report the action taken as either file closed for incompleteness or application denied.

Counteroffers: If the applicant does not accept the counteroffer, report is as a denial on the original terms requested. If the applicant agrees to proceed with the countered terms, report the action taken as originated, or approved but not accepted if the loan does not ultimately close.

Action Taken Date File documentation

Note


Example: 20180721

Originations: Report the account opening or closing date. If the disbursement of funds is later than the closing date (e.g. upon the expiration of rescission), you may report the date of initial disbursement).

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Applications Denied and Files Closed for Incompleteness: Report either the date the action was taken or the date the notice was sent to the applicant.

Withdrawn Application: Report the day the express withdrawal was received or the date shown on the notification form in the case of a written withdrawal.

Approved Not Accepted: Report any reasonable date, such as the approval date, the deadline for accepting the offer or the date the file was closed (Be Consistent in Your Approach)

Construction/Perm: Report either the closing or account opening date or the date the loan converts to permanent financing.

Loan Purchased: Report the date of purchase

Street Address Application

Appraisal or evaluation

Report the street address including secondary address identifier. Cannot be a PO Box.

Example: 456 W Somewhere Ave Apt 201

City Application


Report the name of the city.

Example: Anytown

State Application


Enter the 2-letter state code

Example: CA

ZIP Code Application


Enter the 5 or 9-digit ZIP code

Example: 90049-9998

Report NA if the property address is not known or the address was not provided before the loan was denied, withdrawn, or closed for incompleteness.

County FFIEC Geocoding Site Report the county consistent with historic geocoding rules.

Example: 06037

Census Tract FFIEC Geocoding Site Report the county consistent with historic geocoding rules.

Example: 0637264000

Ethnicity of Applicant

or Borrower

Application or by Visual observation/surname

1. Hispanic or Latino

11. Mexican

12. Puerto Rican

13. Cuban

14. Other Hispanic or Latino

2. Not Hispanic or Latino

3. Information not provided by applicant in mail, internet, or telephone application

4. NA

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If the applicant did not select any ethnicity, but only provided ethnicity in the Free Form Text Field for Other Hispanic or Latino, either leave this data field blank or enter code 14.

Procedural Notes on Ethnicity, Race & Sex

▪ An applicant is not required to select an aggregate category as a precondition to selecting a subcategory.

▪ You should not report an aggregate category if it was not selected by the applicant.

▪ Do not report the ethnicity, race or sex or guarantors.

▪ If there are no co-applicants, you must use the corresponding codes for “No Co-Applicant.”

▪ If there is more than 1 co-applicant, you must report the ethnicity, race, and sex for the only the first co-applicant.

▪ For purchased covered loans, you may report “NA” if you choose not to report the information.

▪ Report “NA” for applicant and/or co-applicants that are not natural persons (LLC, corporation, partnership, etc.)

▪ Report BOTH the aggregate ethnicity and race categories AND the subcategories identified by the applicant.

▪ Preference is given to the aggregate categories. For example, if the applicant selects all 5 aggregate race categories and also selects some race subcategories, you would only report the 5 aggregate race categories.

▪ If the applicant chooses not to provide the information for an application taken in person, not the fact on the collection form and collect the information by visual observation or surname.

▪ If the applicant states on an application or orally that he or she does not wish to provide the information for an application taken by phone, you must report the code for “information not provided by applicant by mail, internet or telephone application.”

Ethnicity of Co-

Applicant or Co-

Borrower


1. Hispanic or Latino

11. Mexican

12. Puerto Rican

13. Cuban

14. Other Hispanic or Latino*

2. Not Hispanic or Latino

3. Information not provided by applicant in mail, internet or telephone application

4. Not applicable

5. No co-applicant

*If this data field does not contain an entry, leave it blank. If the applicant provided ethnicity in the Free Form Text Field for Other Hispanic or Latino and did not select Code 14, either leave the data field blank or enter Code 14.

Ethnicity of Applicant

or Borrower Collected

on the Basis of Visual


1. Collected on the basis of visual observation or surname

2. Not collected on the basis of visual observation or surname

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Observation or

Surname

3. Not applicable

Ethnicity of Co-

Applicant or Co-

Borrower Collected on

the Basis of Visual

Observation or

Surname




3. Not applicable 4. No co-applicant

Race of Applicant or

Borrower


1. American Indian or Alaska Native* 2. Asian

21. Asian Indian

22. Chinese

23. Filipino

24. Japanese

25. Korean

26. Vietnamese

27. Other Asian

3. Black or African American

4. Native Hawaiian or Other Pacific Islander

41. Native Hawaiian

42. Guamanian or Chamorro

43. Samoan

44. Other Pacific Islander*

5. White


7. Not applicable

If the applicant did not enter anything in the free-form text field, either leave this data field blank or enter, as appropriate, Code 1, 27, 44.

Race of Co-Applicant or

Co-Borrower


1. American Indian or Alaska Native* 2. Asian

21. Asian Indian

22. Chinese

23. Filipino

24. Japanese

25. Korean

26. Vietnamese

27. Other Asian

3. Black or African American

4. Native Hawaiian or Other Pacific Islander

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41. Native Hawaiian

42. Guamanian or Chamorro

43. Samoan

44. Other Pacific Islander*

5. White


7. Not applicable

If the co-applicant did not enter anything in the free-form text field, either leave this data field blank or enter, as appropriate, Code 1, 27, 44.

Race of Applicant or

Borrower on the Basis

of Visual Observation

or Surname


1. Collected on the basis of observation or surname 2. Not collected on the basis of observation or surname 3. Not applicable

Race of Co-Applicant or

Co-Borrower on the

Basis of Visual

Observation or

Surname


1. Collected on the basis of observation or surname 2. Not collected on the basis of observation or surname 3. Not applicable 4. No Co-Applicant

Sex of Applicant or

Borrower

Application or by Visual observation

1. Male 2. Female 3. Information not provided by applicant in mail,

internet or telephone application 4. Not applicable

6. Applicant selected both male and female

Sex of Co-Applicant or

Co-Borrower


1. Male 2. Female 3. Information not provided by applicant in mail,

internet or telephone application 4. Not applicable 5. No Co-Applicant 6. Applicant selected both male and female

Sex of Applicant or

Borrower Collected on

the Basis of Visual

Observation or

Surname




3. Not applicable

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Sex of Co-Applicant or

Co-Borrower Collected

on the Basis of Visual

Observation or

Surname




3. Not applicable 4. No Co-Applicant

Age of Applicant or

Borrower

Application, CIP Report the number of whole years from date of birth to the application date.

Example: 24

Code 8888 = Not applicable

Age of Co-Applicant or

Co-Borrower

Application, CIP Report the number of whole years from date of birth to the application date.

Example: 24 Code 8888 = Not applicable

Code 9999 = No Co-Applicant

Income Application

Income Verification

Tax Returns

Pay Stubs

Financial Statements

Income Calculation Worksheet

Enter the gross annual income you relied on in making the credit decision.

Example: 36 or NA

Enter “NA” for non-natural person borrower.

If 2 persons jointly apply for a loan and both list income, but you only rely on the income of one of the applicants in computing ratios and evaluating creditworthiness, report only the income relied upon.

Report “NA” for a loan to an employee.

Report “NA” if income was not considered

Actual distributions from retirement accounts and other assets that you rely on as income should be reported as income.

Type of Purchaser File documentation

Investor agreement

0. Not applicable e.g. denied, withdrawn, approved not accepted, closed for incompleteness

1. Fannie Mae 2. Ginnie Mae 3. Freddie Mac 4. Farmer Mac 5. Private securitizer 6. Commercial bank, savings bank or savings

association

71. Credit union, mortgage company or finance company

72. Life insurance company

8. Affiliate institution

9. Other type of purchaser

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Rate Spread FFIEC Rate Spread Calculator

Report the rate spread for ALL transactions subject to Regulation Z, not just those over the HPML threshold.

Example: 0.428 or NA

Report “NA” for assumptions, reverse mortgages, purchased loans and loans not subject to Regulation Z.

Report “NA” for loans not originated for reasons other than approved not accepted.

HOEPA Status HOEPA Testing Worksheet

1. High-cost mortgage 2. Not a high-cost mortgage 3. Not applicable

Lien Status Title policy, property report or application

1. Secured by a 1st lien 2. Secured by a subordinate lien

Report the lien status (1st or subordinate) of the property identified.

You are required to report the lien status for covered loans originated and purchased and applications that do not result in originations (e.g. preapproval requests approved not accepted, or denied; applications that are approved not accepted, denied, withdrawn or closed for incompleteness).

Procedural Notes for Credit Scores

▪ Report the credit score(s) relied on in making the credit decision even if it was not the dispositive factor.

▪ When you obtained 2+ credit scores for an individual applicant, but relied on only 1 score in making the decision, report the score relied on.

▪ For joint applicants, if you obtain a single credit score and rely on that credit score, report that credit score for the applicant and “NA” for the co-applicant.

▪ If you use more than one scoring model and combine the scores into a composite score, report that score and report that more than one scoring model was used.

▪ Report “NA” for transactions closed for incompleteness or withdrawn before the credit decision was made; transactions for which no credit score was relied upon; purchased covered loans; and, non-natural persons.

Credit Score of

Applicant or Borrower

Credit Report Example: 650

Code 7777 = Credit score not available


Credit Score of Co-

Applicant or Co-

Borrower

Credit Report Example: 650

Code 7777 = Credit score not available


Code 9999 = No Co-Applicant

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Applicant or Borrower,

Name & Version of

Credit Scoring Model

Scoring model 1. Equifax Beacon 5.0 2. Experian Fair Isaac 3. FICO Risk Score Classic 04 4. FICO Risk Score Classic 98 5. VantageScore 2.0 6. VantageScore 3.0 7. More than one credit scoring model 8. Other credit scoring model 9. Not applicable

If Code 8 is entered, specify in text the applicant’s or borrower’s other credit scoring model. Otherwise leave the Free Form Text field blank.

Applicant or Borrower,

Name & Version of

Credit Scoring Model

Scoring model 1. Equifax Beacon 5.0 2. Experian Fair Isaac 3. FICO Risk Score Classic 04 4. FICO Risk Score Classic 98 5. VantageScore 2.0 6. VantageScore 3.0 7. More than one credit scoring model 8. Other credit scoring model 9. Not applicable 10. No Co-Applicant

If Code 8 is entered, specify in text the co-applicant’s or co-borrower’s other credit scoring model. Otherwise leave the Free Form Text field blank.

Reason(s) for Denial File Documentation


1. Debt-to-Income ratio Income insufficient for amount of credit requested, excessive obligations in relation to income

2. Employment history Temporary or irregular employment, length of employment

3. Credit history Insufficient # credit references, unacceptable credit references, no credit, limited credit, poor credit, etc.

4. Collateral Value or type of collateral insufficient

5. Insufficient cash (e.g. downpayment, closing costs, etc.)

6. Unverifiable information Unable to verify credit experience, unable to verify employment, unable to verify income

7. Credit application incomplete

8. Mortgage insurance denied

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9. Other Length at residence, temporary residences, or other

10. Not applicable

Enter as many as 4 principal reasons for denial. If Code 9 is entered, specify in text the Other Reason for Denial. Otherwise, leave the Free Form Text Field blank.

Total Loan Costs Closing Disclosure Example: 2399.04 or NA

Refer to Total Loan Costs, Total Borrower-Paid Origination Charges, Total Points and Fees and Lender Credits.

Total Points and Fees Closing Disclosure Example: 2399.04 or NA

Refer to Total Points and Fees.

Origination Charges Closing Disclosure Example: 2399.04 or NA

Refer to Total Borrower-Paid Origination Charges.

Discount Points Closing Disclosure Example: 2399.04 or NA

Report Total Discount Points Paid.

If no points were paid, leave this field blank.

Lender Credits Closing Disclosure Example: 1500.24 or NA

Refer to Lender Credits Issued.

If no lender credits were provided, leave this field blank.

Interest Rate Note Example 4.125 or NA

Report the interest rate applicable to the approved application or to the covered loan at closing or account opening.

For applications, report interest rate only for those approved not accepted. Enter the code for “NA” for applications that are denied, withdrawn or closed for incompleteness.

Adjustable Rate – Interest Rate Unknown: If the interest rate is unknown at the time the application was approved or at closing, report the fully-index rate on the applicable index.

Prepayment Penalty

Term

Note

Underwriting Document

Example: 24 or NA

Debt-to-Income Ratio Underwriting Documentation

Example: 42.95 or NA

Combined Loan-to-

Value Ratio

Underwriting Documentation

Example 80.05 or NA

13 | P a g e


You are not required to rely on or calculate a combined LTV. If you did not calculate or rely on a combined LTV, report “NA.”

Loan Term Note Example: 360 or NA

Report the loan term as the scheduled number of months after which the legal obligation will mature or terminate or would have matured or terminated.

For a loan with a balloon feature, report the number of months to the final balloon payment, regardless of the amortization basis.

For an open-end line of credit with a definite term, report the number of months from account opening until the account termination date, including both the draw and repayment periods.

Introductory Rate

Period

TRID Disclosures

Home Equity Loan Agreement and Disclosure

Example: 24 or NA

Report the number of months or proposed number of months in the case of an application until the first date the interest rate may change after closing or account opening.

Preferred Rates: Section 1003.4(a)(26) does not require reporting of introductory interest rate period based on preferred rates unless the terms of the legal obligation provide that the preferred rate will expire at a certain defined date.

Report “NA” for fixed rate and purchased loans.

Balloon Payment Note 1. Balloon Payment 2. No Balloon Payment

Interest-Only Payments TRID Disclosures


1. Interest-only payments 2. No interest-only payments

Negative Amortization TRID Disclosures


1. Negative amortization 2. No negative amortization

Other non-Amortizing

Features

TRID Disclosures


1. Other non-fully amortizing features 2. No other non-fully amortizing features

14 | P a g e


Property Value Appraisal or Evaluation, or Purchase Price

Example: 350500 or NA

Field is not rounded.

Report “NA” if no decision was made, even if you obtained a property value (e.g. withdrawn, closed for incompleteness).

Manufactured Home

Secured Property Type

Appraisal 1. Manufactured home and land 2. Manufactured home and not land 3. Not applicable

Manufactured Home

Land Property Interest

Appraisal 1. Direct ownership 2. Indirect ownership 3. Paid leasehold 4. Unpaid leasehold 5. Not applicable

Total Units Appraisal or information provided by applicant

Example: 5

Multifamily Affordable

Units

▪ Information provided by the applicant

▪ Property valuation or inspection

▪ Public records

Example: 5 or NA

Report the number of individuals dwelling units that are income-restricted pursuant to Federal, State or local affordable housing programs.

Submission of

Application

▪ MLO is an employee of your institution

▪ Third party agent

1. Submitted directly to your institution 2. Not submitted directly to your institution 3. Not applicable

Initially Payable to your

Institution

Note or loan contract 1. Initially payable to your institution 2. Not initially payable to your institution 3. Not applicable

Mortgage Loan

Originator NMLSR

Identifier

MLO Listing

NMLS Consumer Access Site

Example: 123450 or NA

If the loan officer does not have an NMLS # (e.g. commercial), enter “NA”

Automated

Underwriting System

Underwriting systems used

1. Desktop Underwriter (DU) 2. Loan Prospector (LP) 3. Technology Open to Approved Lenders (TOTAL)

Scorecard 4. Guaranteed Underwriting System (GUS) 5. Other 6. Not applicable

Enter up to 5 AUS. If Code 5 is entered, use the Free Form Text field to specify the AUS used. Otherwise, leave the Free Form Text field blank.

AUS System Result Results provided from system

1. Approve/Eligible 2. Approve/Ineligible

15 | P a g e


3. Refer/Eligible 4. Refer/Ineligible 5. Refer with Caution 6. Out of Scope 7. Error 8. Accept 9. Caution 10. Ineligible 11. Incomplete 12. Invalid 13. Refer 14. Eligible 15. Unable to Determine 16. Other 17. Not applicable

Enter up to 5 AUS results. If Code 16 is entered, use the Free Form Text field to specify the AUS result. Otherwise, leave the Free Form Text field blank.

Reverse Mortgage Note 1. Reverse mortgage 2. Not a reverse mortgage

Open-End Line of

Credit

Note 1. Open-end line of credit 2. Not an open-end line of credit

Business of Commercial

Purpose

Credit approval memo

1. Primarily for business or commercial purpose 2. Not primarily for business or commercial purpose

HMDA DATA COLLECTIONLOAN FILE AUDIT CHECKLIST

Designated Critical Fields shown in Red

APPLICATION INFORMATION

APPLICANT NAME CO-APPLICANT NAME Unique Loan Identifier (ULI)

Application Date Action Taken Action Taken Date

Loan Amount Purpose Preapproval

Loan Type

DATA RELATED TO THE PROPERTY REPORTED ON THE HMDA LAR

Property Address County

Construction Method Occupancy Type Census Tract

Mfd Home - Prop Type Mfd Home - Land Interest Lien Status

DATA RELATED TO THE PROPERTY SECURING THE LOAN OR LINE OF CREDIT

Property Value Total Units

Combined LTV Multifamily Affordable Units (if 1-4 units, report "NA")

LOAN INFORMATION

Loan Term (mos.) Total Loan Costs Balloon Payment

Interest Rate Total Points and Fees Interest Only Payments

Introductory Rate (mos.) Origination Charges Negative Amortization

Prepayment Penalty (mos.) Discount Points Other Non-amortizing Features

Rate Spread Lender Credits HOEPA Status

APPLICANT INFORMATION

Age Sex

Ethnicity

Race

Credit Score

Ethnicity, Race and/or Sex were

based on visual observation or

surname:

Name and Version of Scoring

Model

CO-APPLICANT INFORMATION

Age Sex

Ethnicity

Race

Credit Score

Ethnicity, Race and/or Sex were

based on visual observation or

surname:

Name and Version of Scoring

Model

UNDERWRITING

Income Debt-to-Income

AUS

AUS System Result

Submission of Application

Initially Payable to Your

Institution MLO NMLS ID

Type of Purchaser

Reasons for Denial

Reverse Mortgage Open-end Line of Credit Business or Commercial Purpose

* Include free-form text fields Created October 28, 2017

Page 1 of 2

The purpose of collecting this information is to help ensure that all applicants are treated fairly and that the housing

needs of communities and neighborhoods are being fulfilled. For residential mortgage lending, Federal law requires

that we ask applicants for their demographic information (e.g. ethnicity, race and sex) in order to monitor our

compliance with equal credit opportunity, fair housing and home mortgage disclosure laws. You are not required to

provide this information, but are encouraged to do so. You may select one or more “Hispanic or Latino” origins

and one or more designations for “race”. The law provides that we may not discriminate on the basis of this

information or on whether you choose to provide it. However, if you choose not to provide the information and

you have made this application in person, Federal regulations require us to note your ethnicity, race and sex on the

basis of visual observation and surname. If you do not wish to provide some or all of this information, please check

below. Check one or more that apply.

APPLICANT CO-APPLICANT

ETHNICITY ETHNICITY

☐ Hispanic or Latino

☐ Mexican

☐ Puerto Rican

☐ Cuban

☐ Other Hispanic or Latino

Print origin below (e.g. Argentinean, Columbian,

Dominican, Nicaraguan, Salvadoran, etc.)

_______________________________________

☐ Not Hispanic or Latino

☐ I do not wish to provide this information.

☐ Hispanic or Latino

☐ Mexican

☐ Puerto Rican

☐ Cuban

☐ Other Hispanic or Latino

Print origin below (e.g. Argentinean, Columbian,

Dominican, Nicaraguan, Salvadoran, etc.)

_______________________________________

☐ Not Hispanic or Latino


RACE RACE

☐ American Indian or Alaska Native

Print name of enrolled or principal tribe.

________________________________________

☐ Asian

☐ Asian Indian

☐ Chinese

☐ Filipino

☐ Japanese

☐ Korean

☐ Vietnamese

☐ Other Asian

Print Race (e.g. Hmong, Laotian, Thai, Pakistani,

Cambodian, etc.)

________________________________________

☐ American Indian or Alaska Native

Print name of enrolled or principal tribe.

________________________________________

☐ Asian

☐ Asian Indian

☐ Chinese

☐ Filipino

☐ Japanese

☐ Korean

☐ Vietnamese

☐ Other Asian

Print Race (e.g. Hmong, Laotian, Thai, Pakistani,

Cambodian, etc.)

________________________________________

HMDA | DEMOGRAPHIC DATA FORM

Page 2 of 2

HMDA | DEMOGRAPHIC DATA FORM

APPLICANT CO-APPLICANT

☐ Black or African American

☐ Native Hawaiian or Other Pacific Islander

☐ Native Hawaiian

☐ Guamanian or Chamorro

☐ Samoan

☐ Other Pacific Islander

Print Race (e.g. Fijian, Tongan, etc.)

________________________________________

☐ White


☐ Black or African American

☐ Native Hawaiian or Other Pacific Islander

☐ Native Hawaiian

☐ Guamanian or Chamorro

☐ Samoan

☐ Other Pacific Islander

Print Race (e.g. Fijian, Tongan, etc.)

________________________________________

☐ White


SEX SEX

☐ Female

☐ Male


☐ Female

☐ Male


To Be Completed by Financial Institution (for an application taken in person):

YES NO

Was the ethnicity of the APPLICANT collected on the basis of visual observation or surname?

☐ ☐

Was the ethnicity of the CO-APPLICANT collected on the basis of visual observation or surname?

☐ ☐

Was the race of the APPLICANT collected on the basis of visual observation or surname?

☐ ☐

Was the race of the CO-APPLICANT collected on the basis of visual observation or surname?

☐ ☐

Was the sex of the APPLICANT collected on the basis of visual observation or surname? ☐ ☐

Was the sex of the CO-APPLICANT collected on the basis of visual observation or surname?

☐ ☐

1 | P a g e

STATED PURPOSE REPORTABLE PURPOSE

Home Purchase and Home Improvement Home Purchase

Home Purchase and Refinancing Home Purchase

Home Purchase and Cash-Out Refinancing Home Purchase

Home Purchase and Other Home Purchase

Home Improvement and Refinancing Refinancing

Home Improvement and Cash-Out Refinancing Cash-Out Refinancing

Refinancing and Other Refinancing

Cash-Out Refinancing and Other Cash-Out Refinancing

Home Improvement and Other Home Improvement

HMDA: Multiple Purpose Loans

S t e r l i ng C O M P L I A N C E , L L C 1 | P a g e

Data Report “NA” for… Reg C Citation

Application Date • Purchased covered loans § 1003.4(a)(1)(ii)

Property Address

• Covered loans or applications if the property

address of the property securing the covered loan is not known (e.g., the property address was not provided to the institution before the application was denied, withdrawn, or closed for incompleteness)

• Covered loans or applications if a site of a manufactured home has not been identified

Comment 4(a)(9)(i)-3

Comment 4(a)(9)-5

State

• Covered loans or applications if the property is not located in a Metropolitan Statistical Area (MSA) or Metropolitan Division (MD) in which the institution has a home or branch office and the institution is not required to report data on small business, small farm, and community development lending under regulations that implement the Community Reinvestment Act of 1977

• Covered loans or applications if the site of a manufactured home has not been identified

§ 1003.4(a)(9)(ii)(A) and § 1003.4(e)

Comment 4(a)(9)-5

County

• Covered loans or applications if the property is

not located in a Metropolitan Statistical Area (MSA) or Metropolitan Division (MD) in which the institution has a home or branch office and the institution is not required to report data on small business, small farm, and community development lending under regulations that implement the Community Reinvestment Act of 1977


§ 1003.4(a)(9)(ii)(B) and § 1003.4(e)

Comment 4(a)(9)-5

Census Tract • Covered loans or applications if the property is

not located in an MSA or MD in which the institution has a home or branch office and the

§ 1003.4(a)(9)(ii)(C) and § 1003.4(e)

2015 HMDA RULE

REPORTING NOT APPLICABLE (“NA”)

EFFECTIVE JANUARY 1, 2018



institution is not required to report data on small business, small farm, and community development lending under regulations that implement the Community Reinvestment Act of 1977

• Covered loans or applications if the property is located in a county with a population of 30,000 or less according to the most recent decennial census conducted by the U.S. Census Bureau


§ 1003.4(a)(9)(ii)(C)

Comment 4(a)(9)-5

Ethnicity, Race, and

Sex of Applicant or Borrower, and/or Co-Applicant or Co-Borrower, and Whether Collected on the Basis of Visual Observation or Surname

• Purchased covered loans for which the

financial institution chooses not to report the applicant’s or co-applicant’s ethnicity, race, and sex

• Covered loans or applications when applicant or co-applicant is not a natural person

Appendix B

Appendix B

Age

• Purchased covered loans for which the financial institution chooses not to report the applicant’s or co-applicant’s age

• Covered loans or applications when applicant

or co-applicant is not a natural person

Comment 4(a)(10)(ii)-3


Income

• Covered loans or applications for which the credit decision did not consider, or would not have considered income

• Covered loans or applications when applicant or co-applicant is not a natural person

• Covered loan is secured by, or application is proposed to be secured by, a multifamily dwelling

• Purchased covered loans for which the

financial institution chooses not to report the income

• Covered loan to, or an application from, the institution’s employees to protect their privacy,

§ 1003.4(a)(10)(iii); Comment 4(a)(10)(iii)-6

Comment 4(a)(10)(iii)-7






even if the institution relied on their income in making the credit decision

Type of Purchaser

• Applications that were denied, withdrawn, closed for incompleteness, or approved but not accepted by the applicant

• Preapproval requests that were denied or approved but not accepted by the applicant

• Originated or purchased covered loans that the

financial institution did not sell during that same calendar year

Comment 4(a)(11)-10

Comment 4(a)(11)-10

Comment 4(a)(11)-10

Rate Spread

• Covered loans that are assumptions, reverse mortgages, purchased loans, or are not subject to Regulation Z

• Applications that did not result in an origination other than approved but not accepted

§ 1003.4(a)(12)(i); Comment 4(a)(12)-7

Comment 4(a)(12)-7

HOEPA Status

• Covered loans not subject to the Home Ownership and Equity Protection Act (HOEPA) of 1994, as implemented in Regulation Z

• Applications that did not result in originations

§ 1026.32(a), § 1003.4(a)(13); Comment 4(a)(13)-1

Comment 4(a)(13)-1

Credit Score for

Applicant or Borrower and/or Co-Applicant or Co-Borrower and Name and Version of Scoring Model

• Purchased covered loans

• Transactions for which no credit decision was

made (e.g., files closed for incompleteness, or if an application was withdrawn before a credit decision was made)

• Transactions for which the credit decision was made without relying on a credit score

• Covered loans or applications when applicant and co-applicant are not natural persons

§ 1003.4(a)(15)(i); Comment 4(a)(15)-6;

Comment 4(a)(15)-4

Comment 4(a)(15)-5

Comment 4(a)(15)-7

Reason for Denial • Applications that were not denied Comment 4(a)(16)-4

Total Loan Costs

• Applications

• Covered loans that are not subject to

Regulation Z

Comment 4(a)(17)(i)-1

§ 1026.43(c), § 1003.4(a)(17)



• Covered loans subject to Regulation Z § 1026.43(c) for which a disclosure is not provided pursuant to § 1026.19(f), such as open-end lines of credit and reverse mortgages.

• Purchased covered loans for which applications were received by the selling entity prior to the effective date of Regulation Z

§ 1003.4(a)(17)

§ 1026.19(f), Comment 4(a)(17)(i)-2

Total Points and Fees

• Applications

• Covered loans that are not subject to Regulation Z




§ 1026.43(c), Comment 4(a)(17)(ii)-1

§ 1026.19(f), § 1003.4(a)(17)(ii)


Origination Charges

• Applications

• Covered loans not subject to Regulation Z


• Purchased covered loans with applications that

were received by the selling entity prior to the effective date of Regulation Z

Comment 4(a)(18)-1

§ 1026.19(f), § 1003.4(a)(18); Comment 4(a)(18)-1

§ 1026.19(f), Comment 4(a)(18)-2

Discount Points

• Applications


• Covered loans subject to Regulation Z §

1026.43(c) for which a disclosure is not provided pursuant to § 1026.19(f), such as open-end lines of credit and reverse mortgages.

• Purchased covered loans with applications that were received by the selling entity prior to the effective date of Regulation Z

Comment 4(a)(19)-1

§ 1026.19(f), § 1003.4(a)(19); Comment 4(a)(19)-1

§ 1026.19(f), Comment 4(a)(19)-2

Lender Credits • Applications Comment 4(a)(20)-1





• Purchased covered loans with applications that

were received by the selling entity prior to the effective date of Regulation Z

§ 1026.19(f), § 1003.4(a)(20); Comment 4(a)(20)-1

§ 1026.19(f), Comment 4(a)(20)-2

Interest Rate • Applications that have been denied, withdrawn,

or closed for incompleteness

Comment 4(a)(21)-2

Prepayment Penalty Term

• Covered loans or applications that are not subject to Regulation Z

• Covered loans or applications that have no prepayment penalty

§ 1026, § 1003.4(a)(22); Comment 4(a)(22)-1

Comment 4(a)(22)-2

Debt-to-Income Ratio


• Transactions for which no credit decision was made (e.g., files closed for incompleteness, or if an application was withdrawn before a credit decision was made)

• Transactions for which the credit decision was

made without relying on debt-to-income ratio


• Covered loan secured by, or an application proposed to be secured by, a multifamily dwelling

§ 1003.4(a)(23); Comment 4(a)(23)-7

Comment 4(a)(23)-3

Comment 4(a)(23)-4

Comment 4(a)(23)-5

Comment 4(a)(23)- 6

Combined Loan-to-

Value Ratio



• Transactions for which the credit decision was made without relying on combined loan-to-value ratio

§ 1003.4(a)(24); Comment 4(a)(24)-5

Comment 4(a)(24)-3

Comment 4(a)(24)-4



Loan Term • Covered loan or application without a definite

term, such as a reverse mortgage

Comment 4(a)(25)-5

Introductory Rate Period

• Covered loan or application with a fixed rate

• Purchased covered loan with a fixed rate

Comment 4(a)(26)-3

Comment 4(a)(26)-4

Property Value


• Transactions for which the credit decision was made without relying on property value

Comment 4(a)(28)-3

Comment 4(a)(28)-4

Manufactured Home Secured Property Type

• The dwelling related to the property identified is not a manufactured home

• The dwelling related to the property identified

is a manufactured home community that is a multifamily dwelling

§ 1003.4(a)(29); Comment 4(a)(29)-4

Comment 4(a)(29)-2; Comment 4(a)(29)-4

Manufactured Home Land Property Interest

• The dwelling related to the property identified is not a manufactured home

• The dwelling related to the property identified is a manufactured home community that is a multifamily dwelling

• A location for the manufactured home related

to a covered loan or application has not been identified

§ 1003.4(a)(30); Comment 4(a)(30)-6

Comment 4(a)(30)-4; Comment 4(a)(30)-6

§ 1003.4(a)(30); Comment 4(a)(9)-5

Multifamily Affordable

Units

• Covered loans or applications where the property securing the covered loan or, in the case of an application, proposed to secure the covered loan is not a multifamily dwelling

§ 1003.4(a)(32); Comment 4(a)(32)-6

Submission of Application

• Purchased covered loans § 1003.4(a)(33)

Initially Payable to Your Institution


• Applications that were withdrawn, denied, or closed for incompleteness, if the institution had not determined whether the covered loans

§ 1003.4(a)(33)




would have been initially payable to the institution reporting the applications

Mortgage Loan

Originator NMLSR Identifier

• Covered loans or applications in which the mortgage loan originator is not required to obtain and has not been assigned an NMLSR identifier

Comment 4(a)(34)-2

Automated Underwriting System (AUS)


• Transactions for which an AUS was not used

to evaluate the application


§ 1003.4(a)(35); Comment 4(a)(35)-5

Comment 4(a)(35)-4

Comment 4(a)(35)-6

Note: The content in this chart is intended to provide guidance concerning when certain information is

reported as not applicable under Regulation C, as amended by the HMDA Rule. Additionally, how to

report “not applicable” may vary depending on the data point. For example, a financial institution may

be instructed to enter “NA”, or enter a specific number value.

The following data points should always be reported (i.e., items in this list should never be reported

as “Not Applicable”):

• Universal Loan Identifier,

• Loan Type, Loan Purpose,

• Preapproval,

• Construction Method, Occupancy Type,

• Loan Amount,

• Action Taken,

• Action Taken Date,

• Lien Status,

• Balloon Payment,

• Interest-Only Payments,

• Negative Amortization,

• Other Non-Amortizing Features,

• Total Units,

• Reverse Mortgage,

• Open-End Line of Credit, and

• Business or Commercial Purpose.

This chart summarizes requirements under HMDA and Regulation C, and does not itself establish any

binding obligations. It is intended only to act as a reference and not as a substitute for the regulation or

its official commentary. Always consult the regulation text and official commentary for a complete

understanding of the law.

Page 1 of 4

This guide was created using the Action Taken Chart provided within the CFPB HMDA Compliance Guide. It is

not intended to be all-inclusive; this guide serves as a quick reference in determining the appropriate action taken.

Note: Customary commitment or closing conditions include: a clear title requirement, an acceptable property survey, acceptable title

insurance, clear termite inspection, a subordination agreement from another lienholder, and, where the applicant plans to use the proceeds

from the home to purchase another, a settlement statement showing adequate proceeds from the sale.

Underwriting or creditworthiness conditions include: conditions that constitute a counter-offer (e.g. demand for a higher down payment),

satisfactory DTI or LTV ratios, a determination of need for private mortgage insurance, a satisfactory appraisal requirement, or

verification or confirmation, in the form the FI requires, that the applicant meets underwriting conditions concerning creditworthiness,

including documentation or verification of income or assets.

REPORTABLE ACTION TAKEN

LOAN ORIGINATED

Scenario Reportable Date

Financial institution (FI) made a credit decision approving an application, including a preapproval request, before loan closing or account opening and that credit decision resulted in a covered loan being originated.

FI made a counteroffer and the applicant accepted resulting in a covered loan being originated.

Generally, loan closing or account opening date

If applicable, it can be: Later date of initial funds disbursement; date the FI acquired the covered loan from the party that initially received the application; or, for a construction-permanent loan, date the covered loan converts to permanent financing.


LOAN PURCHASED


FI purchased a covered loan after closing or account opening and FI did NOT make a credit decision on the application prior to closing or account opening.

FI made a credit decision on an application prior to closing or account opening, but repurchased the covered loan from another entity to which the FI had sold it.

Date of purchase

HMDA | ACTION TAKEN

REFERENCE GUIDE

Page 2 of 4

HMDA | ACTION TAKEN

REFERENCE GUIDE


APPROVED BUT NOT ACCEPTED


FI made a credit decision approving an application before loan closing or account opening, all conditions were satisfied, FI agreed to extend credit, but a covered loan was not originated.

FI made a credit decision approving an application subject to conditions that are solely customary commitment or closing conditions and the conditions were not all met.

FI made a credit decision approving an application, subject solely to outstanding conditions that are customary commitment or closing conditions, but the applicant failed to respond or a covered loan was not originated.

FI made a credit decision approving an application, all underwriting and creditworthiness conditions were met, outstanding conditions were solely customary commitment or closing conditions and applicant expressly withdrew before a covered loan was originated.

Covered loan was originated, but borrower rescinded after closing and before FI was required to submit its LAR containing information for the covered loan.

Any reasonable date, such as approval date, deadline for accepting offer or date file was closed


APPLICATION DENIED


FI denied an application before applicant withdrew it and before the file was closed for incompleteness.

FI made a counteroffer ad applicant did not accept the counteroffer or failed to respond.

FI provided conditional approval specifying underwriting or creditworthiness conditions that were not all met.

Date application is denied or date notice was sent to the applicant(s)

Page 3 of 4

HMDA | ACTION TAKEN

REFERENCE GUIDE


APPLICATION WITHDRAWN


Application was expressly withdrawn by the applicant before the FI made a credit decision denying or approving the application and before the file was closed for incompleteness.

FI provided conditional approval specifying underwriting or creditworthiness conditions, and the application was expressly withdrawn by the applicant before the applicant satisfied all specified underwriting or creditworthiness conditions and before the FI denied the loan or closed the file for incompleteness.

Date the express withdrawal was received or date shown on the notification form (if withdrawal request was written)


FILE CLOSED FOR INCOMPLETENESS1


FI approved an application, subject to underwriting and creditworthiness conditions, sent notice of incompleteness under Reg. B, but the applicant failed to respond within the specified timeframe.

Applicant had not satisfied all underwriting or creditworthiness conditions, FI sent notice of incompleteness under Reg. B and the applicant did not respond to the request for additional information within the period of time specified in the notice.

Date file was closed or date notice was sent to the applicant(s)


EITHER FILE CLOSED FOR INCOMPLETENESS OR APPLICATION DENIED


Applicant had not satisfied all underwriting or creditworthiness conditions, FI sent written notice of incompleteness under Reg. B, the applicant did not respond, then the FI provided notice of adverse action on basis of incompleteness under Reg. B.

Date file was closed, application was denied (as applicable), or notice sent to applicant

1 A preapproval request that is closed for incompleteness is not reportable under HMDA

Page 4 of 4

HMDA | ACTION TAKEN

REFERENCE GUIDE


PREAPPROVAL REQUEST APPROVED BUT NOT ACCEPTED


Application was a request for a preapproval under a preapproval program, the FI approved the preapproval request, but the application did not result in the FI originating a covered loan.

Any reasonable date, such as approval date, deadline for accepting offer or date file was closed.


PREAPPROVAL REQUEST DENIED


Application was a request for a preapproval under a preapproval program and the FI made a credit decision denying the preapproval request.

Date preapproval request was denied or date notice was sent to the applicant(s).

1 | P a g e

QUESTION ANSWER

Effective January 1, 2018, do we need to display the old notice AND the new notice?

No. You only need to display the new notice.

If you go to https://www.consumerfinance.gov/data-research/hmda/, you can get to prior years’ HMDA Disclosures. Even though we are not using the CFPB’s HMDA platform to submit HMDA LAR data until we file the 2017 HMDA LAR, the older data is still available through their website.

We received an application in the mail and the borrower checked “I do not wish to furnish this information”, as well as checking their sex, race and ethnicity. What should be reported?

When an applicant provides the requested information for some but not all fields, you report the information that was provided by the applicant, whether partial or complete. If an applicant provides partial or complete information on ethnicity, race, and sex and also checks the “I do not wish to provide this information” box on an application that is taken by mail or on the internet, or makes that selection when applying by telephone, you must report the information on ethnicity, race, and sex that was provided by the applicant

Must the demographic information form that we use ask if the information was provided through face-to-face interview, telephone interview or fax/email/internet? The model form includes an option to indicate whether an application was taken in person and, if so, whether demographic information was taken on the basis of visual observation.

It is not mandated by regulation. However, since it is only requiring a tick mark indicator, it’s simple enough to include it and further confirm the application process.

When an Internet application shows demographic information marked “I do not wish to provide”, and the applicant comes to the office to meet with the lender a couple days later, do we indicate

It depends. Demographic information is collected at the time of application. If you receive a completed application online or by phone, and the applicant has indicated that they do not wish

HMDA: Common Q&A

https://www.consumerfinance.gov/data-research/hmda/

https://www.consumerfinance.gov/data-research/hmda/

2 | P a g e

QUESTION ANSWER

the aggregate demographic data based on visual observation?

to provide the information, you should report it that way, even if you meet them in person some time later. Only if you meet them face to face to complete the application would you then use visual observation to record demographic information. Once you're processing an application - once you've issued the LE, for example - you're no longer in the application phase for purposes of collecting demographic information. Remember - it's OK to report that the applicant "did not wish to provide" for an application taken by phone, email or Internet.

When we have a joint application for unmarried applicants, we have always completed two separate 1003s. Do we collect demographic information for both applicants?

Yes. The applicants’ marital status has no bearing on whether you collect and report demographic information on a co-applicant. You collect demographic information for the applicant and the first co-applicant, if there is more than one. LOS system parameters may impact how this is done. If it does not provide for this data collection, you may want to reconsider completing separate applications

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CFPB RESOURCE URL

HMDA Rule Implementation Page https://www.consumerfinance.gov/policy-compliance/guidance/implementation-guidance/hmda-implementation/

HMDA Rule https://www.consumerfinance.gov/policy-compliance/rulemaking/final-rules/regulation-c-home-mortgage-disclosure-act/

Small Entity Compliance Guide https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/cfpb_hmda_small-entity-compliance-guide.pdf

2018 Institutional Coverage Chart https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201709_cfpb_2018-hmda-institutional-coverage.pdf

2018 Transactional Coverage Chart https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201709_cfpb_2018-hmda-transactional-coverage.pdf

Reportable Data Reference Chart https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201710_cfpb_reportable-hmda-data_regulatory-and-reporting-overview-reference-chart.pdf

Reporting Information about Race and Ethnicity

https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201701_cfpb_hmda_ethnicity-and-race-collection_v2.pdf

Webinar Information Webinar 1: https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/HMDA_Webinar.pdf

Webinar 2:

https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201702_cfpb_HMDA-Webinar-2-presentation.pdf

Sample Demographic Data Collection Form

https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201708_cfpb_hmda-sample-data-collection-form.pdf

Data Submission Resources https://www.consumerfinance.gov/data-research/hmda/for-filers

HMDA Platform https://ffiec.cfpb.gov/

Rate Spread Calculator https://cfpb.github.io/hmda-platform-tools/rate-spread/

HMDA: CFPB Resources

https://www.consumerfinance.gov/policy-compliance/guidance/implementation-guidance/hmda-implementation/

https://www.consumerfinance.gov/policy-compliance/guidance/implementation-guidance/hmda-implementation/

https://www.consumerfinance.gov/policy-compliance/rulemaking/final-rules/regulation-c-home-mortgage-disclosure-act/

https://www.consumerfinance.gov/policy-compliance/rulemaking/final-rules/regulation-c-home-mortgage-disclosure-act/

https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/cfpb_hmda_small-entity-compliance-guide.pdf

https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/cfpb_hmda_small-entity-compliance-guide.pdf

https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201709_cfpb_2018-hmda-institutional-coverage.pdf

https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201709_cfpb_2018-hmda-institutional-coverage.pdf

https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201709_cfpb_2018-hmda-transactional-coverage.pdf

https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201709_cfpb_2018-hmda-transactional-coverage.pdf

https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201710_cfpb_reportable-hmda-data_regulatory-and-reporting-overview-reference-chart.pdf





https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/HMDA_Webinar.pdf

https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/HMDA_Webinar.pdf





https://www.consumerfinance.gov/data-research/hmda/for-filers

https://ffiec.cfpb.gov/

https://cfpb.github.io/hmda-platform-tools/rate-spread/

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CFPB RESOURCE URL

Check Digit Tool https://cfpb.github.io/hmda-platform-tools/check-digit/

HMDA Self Service Knowledge Portal

https://hmdahelp.consumerfinance.gov/knowledgebase/s/

2018 Filing Instructions Guide https://www.consumerfinance.gov/data-research/hmda/static/for-filers/2018/2018-HMDA-FIG.pdf

HMDA Loan Scenarios https://www.consumerfinance.gov/data-research/hmda/static/for-filers/HMDA-Loan-Scenarios.pdf

FAQs https://www.consumerfinance.gov/data-research/hmda/faq

https://cfpb.github.io/hmda-platform-tools/check-digit/

https://hmdahelp.consumerfinance.gov/knowledgebase/s/

https://www.consumerfinance.gov/data-research/hmda/static/for-filers/2018/2018-HMDA-FIG.pdf

https://www.consumerfinance.gov/data-research/hmda/static/for-filers/2018/2018-HMDA-FIG.pdf

https://www.consumerfinance.gov/data-research/hmda/static/for-filers/HMDA-Loan-Scenarios.pdf

https://www.consumerfinance.gov/data-research/hmda/static/for-filers/HMDA-Loan-Scenarios.pdf

https://www.consumerfinance.gov/data-research/hmda/faq

Documents

HMDA REFERENCE GUIDE - Sterling Compliancesterlingcompliancellc.com/wp-content/uploads/2018/01/HMDA-REFERENCE-GUIDE.pdfHMDA Reference Guide IN THIS GUIDE The documents within this