By, Gina Ellis
Beginning in 2018, HMDA reporters will be required to collect, record and report numerous new data points for originations, purchases and applications of covered loans. New information about applicants will include reporting age, credit score, debt to income ratio and combined loan to value ratio.
Additional information about the loan process will include whether the application was submitted directly to the financial institution, whether the loan was initially payable to the financial institution and the name and results of the automated underwriting system used to evaluate the application.
New information about the property securing the loan will include the value relied on and the type of property, such as a manufactured home with or without land. Information reported will also indicate whether the applicant owns or leases the land where the manufactured home is located. The number of individual dwelling units related to the collateral property and the number of units that are income restricted under federal, state or local affordable housing programs will also need to be reported. The physical address of the property securing the loan or to be secured will also be required.
Loan costs and fees will also be reported for applications that result in originations. These new data points include the total loan costs or total points and fees charged, total borrower paid origination charges, discount points and the amount of any lender credits. The interest rate and any introductory rate period will be required along with any prepayment term, the number of months to final maturity and whether the transaction involves any non-amortizing features including balloon, interest only payments or negative amortization.
The mortgage loan originator identification number assigned by the National Mortgage Licensing System and Registry (NMLSR) will be required to be reported. Financial institutions will also be required to indicate whether a covered transaction is a reverse mortgage, open end line of credit, or business or commercial purpose.
As you can see, the new reporting obligations are extensive and will require significant changes to systems and processes to achieve compliance.