By: Elva Coffey-Sears
In addition to the 25 new HMDA data points previously discussed, the CFPB has modified many of the existing data points. However, not all have changed including those relating to application date, loan type, action taken, property location, income and HOEPA status.
The CFPB’s Summary of Reportable HMDA Data – Regulatory Reference Chart provides a listing of all 2018 data points identifying which are modified, existing or new, while referencing the regulatory citation for each. The CFPB’s chart does not, however, describe the changes applicable to each of the modified data points.
While full details of the changes are provided in the CFPB’s Small Entity Compliance Guide and in the Section-by-Section Analysis in the Federal Register, we thought we’d share this chart summarizing the data point changes:
2018 HMDA Modified Data Fields
|Data Point||Summary of Change|
|Application or Loan Number||Adds the institution’s Legal Entity Identifier and a two-character check digit generated as prescribed in Appendix C to the 23 characters (letters and/or numbers) that are unique to the loan or application|
|Loan Purpose||Expanded to include cash-out refinancing and other, in addition to home purchase, home improvement and refinancing|
|Preapproval||Requires reporting of all applications for home purchase loans under a preapproval program, regardless of action taken|
|Construction Method||Changed from requiring the type of property to which the application related to reporting as either “site-built” or “manufactured home”|
|Occupancy Type||Modified reporting categories to principal residence, second residence or investment property|
|Loan Amount||Expanded to include clarification of amount required to be reported for home equity lines of credit and reverse mortgages|
|Ethnicity, Race, and Sex||Introduces requirement to report whether or not the information was obtained on the basis of visual observation or surname and allows applicants to report disaggregated ethnic and racial subcategories|
|Type of Purchaser||Separates the life insurance company from the credit union, mortgage bank or finance company category|
|Rate Spread||Removes the 1.5 percentage point first-lien and 3.5 percentage point subordinate-lien thresholds for reporting rate spread on covered loans.
Requires reporting for approved not accepted applications.
|Lien Status||Limits categories to first-lien and subordinate lien and requires reporting of lien status for purchased loans|
|Reason for Denial||Imposes requirement to report reason for denial on all financial institutions and requires free-form entry of the specific reason in conjunction with the “other” category|
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