HMDA REFERENCE GUIDE - Sterling Compliance LLC

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COMPLIANCE

HMDA REFERENCE GUIDE

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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

HMDA Reference Guide

HMDA | REPORTABLE DATA BREAKDOWN

DATA POINT

DESCRIPTION

Legal Entity Identifier (LEI)

Identifier issued to the financial institution (FI) by a utility endorsed by the Global LEI Foundation or LEI Regulatory Oversight Committee

Universal Loan Identifier (ULI)

Identifier assigned to identify and retrieve a loan or application that contains the FI's LEI, an internally generated sequence of characters and a check digit

Application Date

Date the application was received or the date on the application form

Loan Type

Indicates whether the loan or application is insured by the Federal Housing Administration, guaranteed by the Veterans Administration, Rural Housing Service or Farm Service Agency

Loan Purpose

Preapproval Construction Method Occupancy Type Loan Amount

Indicates whether the transaction is for a home purchase, home improvement, refinancing, cash-out refinancing or another purpose Indicates whether the transaction involved a preapproval request for a home purchase loan under a preapproval program Indicates whether the dwelling is site-built or a manufactured home Indicates whether the property will be used as a principal residence, second residence or investment property Amount of the loan or the amount for which the consumer applied

Action Taken

Type of action taken on the loan, application or preapproval request

Action Taken Date

Date of action taken on the loan, application or preapproval request

Property Address

Address of the property securing the loan or proposed to secure the loan

Property Location

Ethnicity, Race & Sex Age

Income

Type of Purchaser Rate Spread HOEPA Status Lien Status Credit Score Reason for Denial

Location of the property securing the loan or proposed to secure the loan by state, county and census tract Applicant's or borrower's ethnicity, race and sex. Also, indicates whether this information was collected by visual observation or surname Applicant's or borrower's age If credit decision is made = gross annual income relied on in making the credit decision. If credit decision is not made = gross annual income relied on in processing the application. Type of entity that purchased the loan Difference between the APR and average prime offer rate for a comparable transaction Indicates whether the loan is a high-cost mortgage under the Home Ownership and Equity Protection Act Indicates whether the lien is a first or subordinate lien Credit score(s) relied upon and the name and version of the credit scoring model Reason(s) the application was denied

Total Loan Costs or Total Points & Fees

Either total loan costs or total points and fees charged

STATUS REGULATORY REFERENCE

MODIFIED

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

MODIFIED EXISTING

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

Appendix C 1003.4(a)(1)(ii) Comments 4(a)(1)(ii)-1 through 3

EXISTING

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

MODIFIED

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

MODIFIED

1003.4(a)(4) Comments 4(a)(4)-1 and 2

MODIFIED

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

MODIFIED

1003.4(a)(6) Comments 4(a)(6)-1 through 5

MODIFIED

1003.4(a)(7) Comments 4(a)(7)-1 through 9

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

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

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

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

NEW

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

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

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

MODIFIED

1003.4(a)(10)(i) Comments 4(a)(10)(i)-1 and 2 and

Appendix B

NEW

1003.4(a)(10)(ii) Comments 4(a)(10)(ii)-1 through 5

EXISTING

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

MODIFIED MODIFIED EXISTING MODIFIED

NEW MODIFIED

NEW

1003.4(a)(11) Comments 4(a)(11)-1 through 10

1003.4(a)(12) Comments 4(a)(12)-1 through 8

1003.4(13) Comment 4(a)(13)-1

1003.4(a)(14) Comments 4(a)(14)-1 and 2

1003.4(a)(15) Comments 4(a)(15)-1 through 7

1003.4(a)(16) Comments 4(a)(16)-1 through 4

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 Origination Charges

DESCRIPTION Total borrower-paid origination charges

STATUS NEW

Discount Points

Points paid to the creditor to reduce the interest rate

NEW

Lender Credits

Amount of lender credits

NEW

Interest Rate

Interest rate o the approved application or loan

NEW

Prepayment Penalty Term Term in months of any prepayment penalty

Debt-to-Income Ratio

Ratio of the applicant's or borrower's total monthly debt to total monthly income relied on

Combined Loan-to-Value Ratio of the total amount of debt that is secured by the property

Ratio

to the value of the property that was relied on

Loan Term

Number of months after which the legal obligation will mature or terminate

Introductory Rate Period

Number of months until the first date the interest rate may change

Indicates whether the transaction involves a balloon payment, Non-Amortizing Features interest-only payments, negative amortization or ay other type of

non-amortizing feature

Property Value

Value of the property relied on that secures the loan

NEW NEW NEW NEW NEW

NEW

NEW

Manufactured Home

Indicates whether the covered loan is secured by a manufactured

Secured Property Type home and land or a manufactured home with no land

Manufactured Home Land Property Interest

Information about the applicant's or borrower's ownership or leasehold interest in the land where the manufactured home is located

Total Units

Number of individual dwelling units related to the property

Multifamily Affordable Units

Number of individual dwelling units related to the property that are income-restricted under federal, state or local affordable housing programs

Application Channel

Indicates whether the application was submitted directly to the FI and whether the obligation was initially payable to the FI

Mortgage Loan Originator NMLSR Identifier

National Mortgage Licensing System Registry (NMLSR) identifier for the MLO

Automated Underwriting Name of the automated underwriting system used by the FI to

System

evaluate the application and the result generated by that system

Reverse Mortgage

Indicates of whether the transaction is for a reverse mortgage

Open-End Line of Credit Indicates whether the transaction is for an open-end line of credit

Business or Commercial Indicates whether the transaction is primarily for a business or

Purpose

commercial purpose

NEW

NEW NEW NEW

NEW

NEW NEW NEW NEW NEW

REGULATORY REFERENCE 1003.4(a)(18)

Comments 4(a)(18)-1 through 3 1003.4(a)(19)

Comments 4(a)(19)-1 through 3 1003.4(a)(20)

Comments 4(a)(20)-1 through 3 1003.4(a)(21)

Comments 4(a)(21)-1 through 3 1003.4(a)(22)

Comments 4(a)(22)-1 through 2 1003.4(a)(23)

Comments 4(a)(23)-1 through 7 1003.4(a)(24)

Comments 4(a)(24)-1 through 5 1003.4(a)(25)

Comments 4(a)(25)-1 through 5 1003.4(a)(26)

Comments 4(a)(26)-1 through 4

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

1003.4(a)(28) Comments 4(a)(28)-1 through 4

1003.4(a)(29) Comments 4(a)(29)-1 through 4

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

1003.4(31) Comments 4(a)(3)-1 through 4

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

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

and 4(a)(33)(ii)-1 through 2

1003.4(a)(34) Comments 4(a)(34)-1 through 3

1003.4(a)(35) Comments 4(a)(35)-1 through 6

1003.4(a)(36) 1003.4(a)(37) Comment 4(a)(37)-1 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 is intended 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 it address any of the exceptions that are found in the HMDA Rule.

HMDA | DESIGNATED KEY FIELDS

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 # 3 4 5 6 9 10 11 12 18 19 25 33 34 41 42 51 52 55 56 57 61 62

Data Field Name

Universal Loan Identifier (ULI) Application Date Loan Type Loan Purpose Occupancy Type Loan Amount Action Taken Action Taken Date Census Tract Ethnicity of Applicant or Borrower: 1 Ethnicity of Co-Applicant or Co-Borrower: 1 Race of Applicant or Borrower: 1 Race of Applicant or Borrower: 2 Race of Co-Applicant or Co-Borrower: 1 Race of Co-Applicant or Co-Borrower: 2 Sex of Applicant or Borrower Sex of Co-Applicant or Co-Borrower Age of Applicant or Borrower Age of Co-Applicant or Co-Borrower Income Lien Status Credit Score of Applicant or Borrower

Data Point Name

Universal Loan Identifier (ULI) Application Date Loan Type Loan Purpose Occupancy Type Loan Amount Action Taken Action Taken Date Property Location Ethnicity Ethnicity Race Race Race Race Sex Sex Age Age Income Lien Status Credit Score

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

Sterling COMPLIANCE, LLC

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Field # 63

75 76 77 78 80 81 82 88 89

Data Field Name

Credit Score of Co-Applicant or CoBorrower Origination Charges Discount Points Lender Credits Interest Rate Debt-to-Income Ratio Combined Loan-To-Value Ratio Loan Term Property Value Manufactured Home Secured Property Type

91 Total Units 102 Automated Underwriting System Result: 1 108 Reverse Mortgage 109 Open-End Line of Credit 110 Business or Commercial Purpose

Data Point Name

Credit Score

Origination Charges Discount Points Lender Credits Interest Rate Debt-to-Income Ratio Combined Loan-To-Value Ratio Loan Term Property Value Manufactured Home Secured Property Type Total Units Automated Underwriting System Reverse Mortgage Open-End Line of Credit Business or Commercial Purpose

Sterling COMPLIANCE, LLC

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HMDA PROCEDURES

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

Legal Entity Identifier (LEI)

Universal Loan Identifier (ULI)

Source Document

LEI Registration Call Report

Internal methodology

Procedure

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

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.

Application Date

Uniform Residential Loan Application (1003)

Home Equity Application, if other than URLA

Commercial Loan Application

Commercial Loan Write-up

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.

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

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Data Point

Source Document Procedure

Loan Type

Application

Loan Purpose

Application Commercial Loan

Write-up

Preapproval

File documentation of preapproval request

Formal preapproval request if applicable

Construction Method Appraisal or evaluation

Occupancy Type

Application or credit write-up

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.

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)

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.

1. Preapproval requested 2. Preapproval not requested

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

1. Site-built 2. Manufactured Home

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

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

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

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