HMDA DATA COLLECTION FORMS - FILLABLE (UPDATED) - for Exempt Banks and Non-Exempt Banks

VP at a bank ($470MUSA)
I have shared these forms in the past, but had some CBANC colleagues ask for some enhancements.  So with the help of others, I think we finally have these forms where anyone can use them.  They still come with a disclaimer that they have not been approved by examiners or an attorney.  Use at your own risk.  The order of the items on the worksheet goes along with the order they would be entered in the CFPB LAR.  Not perfect, but the best I could do trying to keep to 4 pages. 

    HMDA Data Collection Form for Exempt Banks - Fillable File (Updated)

    VP at a bank ($470MUSA)
    I shared this form a few days ago.  I had the income field formatted to numbers only.  Since we sometimes need to use "NA" for an employee application,  I reformatted that field.  If anyone finds other changes they think would make this form more useable please send me a note and I can try to make the changes for you. 

      7 of the most confusing areas of compliance, explained! (plus lots of resources)

      Confounded by Community Development? Perplexed by UDAAPs? Baffled by Beneficial Ownership? Flummoxed by Fair Lending discrimination? If so, you're not alone! Here are 7 compliance topics that are widely regarded as the most complex - with tips, tricks, and lots of great resources to help make them easier to manage. Read the post here:

        10 things you need to do now that your HMDA is filed

        It's that time of year again - your HMDA data has been filed with the federal government. The regulators have your HMDA (and CRA) LAR now, so the time is ripe for you to take a deep breath and think about your goals for the rest of the year.

        Now that you've filed your HMDA data, here are the 10 things you need to do:

          HMDA HOEPA Status

          VP at a bank ($532MUSA)

          If the loan is in the name of a trust and the primary residence is the collateral, for the HOEPA status should we report a 1 or 2 in the field? It states that if consumer purpose report a 1 or 2. However, since a Trust is not a person do you state a status or is it not applicable, like a loan to a business?
          Thank you

            AUS Risk Assessment

            AVP at a bank ($997MUSA)

            Needing guidance on how to report a loan which received an AUS approve eligible but was subsequently denied due to collateral (something AUS can't read such as mold, etc)? Do you list the AUS approve eligible then list a 2nd risk assessment such as "Other" or show "Not Applicable" as the only AUS finding? Thanks

              HMDA Reporting for Purchased Puerto Rico loans

              VP at a bank ($560MUSA)

              We are a first time HMDA reporter and will be filing with the small filer exemptions. We have purchased a pool of loans located in Puerto Rico. We cannot pull our usual census tract information but will need to gather the longitude/latitude and use a special site to obtain this information. Is anyone aware of any exemption for census information for purchased loans located in Puerto Rico? Appreciate any advice on this.

                7 Facts about the CFPB's Recent HMDA Rule Update

                It seems like there is a regulatory update to the Home Mortgage Disclosure Act every minute! Just last month, the CFPB released updated information about the HMDA data that will be disclosed in 2019. If you're a HMDA reporter, this post is for you. Plus, you'll also get access to a new-and-improved version of our insanely popular Guide to the HMDA Changes! Don't miss it.


                  Encompass HMDA - APR

                  AVP at a bank ($3.4BUSA)

                  Good morning everyone,

                  Looking for guidance from other HMDA reporters that use Encompass.

                  Currently, in Encompass, we are using the Mavent auto-populating setting to populate our Rate Spread Calculations for HMDA reporting. Every time we run Mavent, it calculates the Rate Spread and populates it to the HMDA info screen, which populates to our LAR. The problem we are encountering is that the APR that Mavent is using to calculate the Rate Spread is the one it calculates (based on fee mapping), and this value is not always the same as the value that we are disclosing on our CD, which is where the Reg tells us to get the APR. This can happen for a number of reasons, most of which deal with known limitations of Mavent. Our disclosed APR is correct, but the calculated rate is not. Most often it is with Construction-Perm loans. There are also issues with fees being mapped differently in Mavent, than how the fee is being paid or used in the loan. Finally, there appear to be some rounding issues.

                  All of these issues would not cause problems with Rate Spread if Encompass calculated it based off the Disclosed APR instead of the APR it is calculating.

                  What we want to know is:
                  • Can we change this setting on the user end to use the disclosed instead of calculated value?
                  • If not, what is the Ellie Mae logic in using the calculated value when the Reg seems to be clear that the disclosed value should be used?

                  Have any of you worked through this? All input appreciated!

                    HMDA - Reporting Number of Units

                    VP at a bank ($637MUSA)

                    We have a property with a primary residence and also a guest cottage. The guest cottage is currently not habitable without repairs being made but there is no plans to repair. Do we report 1 unit or 2 units for total units?

                    We have a property with multiple dwellings (rentals). One of the dwellings on the property is currently being built but the loan is not a construction loan. The roof and outside walls are in place but the dwelling isn't finished on the inside yet. Do we include this dwelling in our count for number of units?