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787078-115748HMDA PROCEDURES 00HMDA PROCEDURES -366712-35242500DATA COLLECTIONThe 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 PointSource DocumentProcedureLegal Entity Identifier (LEI)LEI Registration Call ReportEnter your institution’s LEI. Width specification: 20 charactersUniversal Loan Identifier (ULI)Internal methodologyEnter the ULI for the transaction based on your internal methodologyWidth specification: 45 charactersOne the ULI is assigned, it stays with the loan. If you previously reported a covered loan with a ULI, a financial institution that purchases that covered loan must use the ULI that was previously reported.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 DateUniform Residential Loan Application (1003)Home Equity Application, if other than URLACommercial Loan ApplicationCommercial Loan Write-upReport 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 mercial 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: 20180721For 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.If you are treating 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 TypeApplicationConventional Not insured or guaranteed by FHA, VA, RHS or FSAFederal Housing Administration Insured (FHA)Veterans Affairs Guaranteed (VA)USDA Rural Housing Service or Farm Service Agency Guaranteed (RHS or FSA)Loan PurposeApplicationCommercial Loan Write-upHome PurchaseHome Improvement31. Refinancing32. Cash-out Refinancing4. Other Purpose5. Not ApplicableDocumentation of loan purpose within application or commercial loan write-up should be SPECIFIC.PreapprovalFile documentation of preapproval requestFormal preapproval request if applicablePreapproval requestedPreapproval not requestedBe sure your processes are well-defined between pre-qualifications and preapprovals. Pre-qualifications are not reportable.Construction MethodAppraisal or evaluationSite-builtManufactured HomeModular 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 TypeApplication or credit write-upPrincipal residenceSecond residenceInvestment propertyFor 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.Loan AmountNoteEnter the loan amount.Example: 110500 or 100500.00The field is no longer roundedFor a closed-end mortgage, other than a purchased loan, an assumption or a reverse mortgage, the amount to be repaid as disclosed on the 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.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 TakenFile documentationNoteAdverse Action NoticeLoan originatedApplication approved but not acceptedApplication deniedApplication withdrawn by applicantFile closed for incompletenessPurchased loanPreapproval request deniedPreapproval request approved but not acceptedIf 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 on that application.Action Taken DateFile documentationNoteAdverse Action NoticeExample: 20180721Originations: 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).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 purchaseStreet AddressApplication Appraisal or evaluationReport the street address including secondary address identifier.Example: 456 W Somewhere Ave Apt 201CityApplication Appraisal or evaluationReport the name of the city.Example: AnytownStateApplication Appraisal or evaluationEnter the 2-letter state codeExample: CAZIP CodeApplication Appraisal or evaluationEnter the 5 or 9-digit ZIP codeExample: 90049-9998Report NA if the property address is not known or the address was not provided before the loan was denied, withdrawn, or closed for incompleteness.CountyFFIEC Geocoding SiteReport the county consistent with historic geocoding rules.Example: 06037Census TractFFIEC Geocoding SiteReport the county consistent with historic geocoding rules.Example: 0637264000Ethnicity of Applicant or BorrowerApplication or by Visual observation/surnameHispanic or Latino11. Mexican12. Puerto Rican13. Cuban14. Other Hispanic or Latino2. Not Hispanic or Latino3. Information not provided by applicant in mail, internet, or telephone application4. NAIf 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 & SexAn 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-BorrowerApplication or by Visual observation/surnameHispanic or Latino11. Mexican12. Puerto Rican13. Cuban14. Other Hispanic or Latino2. Not Hispanic or Latino3. Information not provided by applicant in mail, internet or telephone application4. Not applicable5. No co-applicantIf this data field does not contain an entry, leave it blank. If the application 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 Observation or SurnameApplication or by Visual observation/surnameCollected on the basis of visual observation or surnameNot collected on the basis of visual observation or surnameNot applicableEthnicity of Co-Applicant or Co-Borrower Collected on the Basis of Visual Observation or SurnameApplication or by Visual observation/surnameCollected on the basis of visual observation or surnameNot collected on the basis of visual observation or surnameNot applicableNo co-applicantRace of Applicant or BorrowerApplication or by Visual observation/surnameAmerican Indian or Alaska NativeAsian21. Asian Indian22. Chinese23. Filipino24. Japanese25. Korean26. Vietnamese27. Other Asian3. Black or African American4. Native Hawaiian or Other Pacific Islander41. Native Hawaiian42. Guamanian or Chamorro43. Samoan44. Other Pacific Islander5. White6. Information not provided by applicant in mail, internet or telephone application7. Not applicableIf the applicant or borrower did not select any race and only provide race in the Race of Applicant or Borrower Free Form Text Field for American Indian or Alaska Native Enrolled in Principal Tribe, Race of Applicant or Borrower Free Form Text Field for Other Pacific Islander, either leave this data field blank or enter, as appropriate, Code 1, 27, 44.Race of Co-Applicant or Co-BorrowerApplication or by Visual observation/surnameAmerican Indian or Alaska NativeAsian21. Asian Indian22. Chinese23. Filipino24. Japanese25. Korean26. Vietnamese27. Other Asian3. Black or African American4. Native Hawaiian or Other Pacific Islander41. Native Hawaiian42. Guamanian or Chamorro43. Samoan44. Other Pacific Islander5. White6. Information not provided by applicant in mail, internet or telephone application7. Not applicableIf the applicant or borrower did not select any race and only provide race in the Race of Co-Applicant or Co-Borrower Free Form Text Field for American Indian or Alaska Native Enrolled in Principal Tribe, Race of Co-Applicant or Co-Borrower Free Form Text Field for Other Pacific Islander, 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 SurnameApplication or by Visual observation/surnameCollected on the basis of observation or surnameNot collected on the basis of observation or surnameNot applicableRace of Co-Applicant or Co-Borrower on the Basis of Visual Observation or SurnameApplication or by Visual observation/surnameCollected on the basis of observation or surnameNot collected on the basis of observation or surnameNot applicableNo Co-ApplicantSex of Applicant or BorrowerApplication or by Visual observationMaleFemaleInformation not provided by applicant in mail, internet or telephone applicationNot applicable6. Applicant selected both male and femaleSex of Co-Applicant or Co-BorrowerApplication or by Visual observationMaleFemaleInformation not provided by applicant in mail, internet or telephone applicationNot applicableNo Co-ApplicantApplicant selected both male and femaleSex of Applicant or Borrower Collected on the Basis of Visual Observation or SurnameApplication or by Visual observation Collected on the basis of visual observation or surnameNot collected on the basis of visual observation or surnameNot applicableSex of Co-Applicant or Co-Borrower Collected on the Basis of Visual Observation or SurnameApplication or by Visual observationCollected on the basis of visual observation or surnameNot collected on the basis of visual observation or surnameNot applicableNo Co-ApplicantAge of Applicant or BorrowerApplicationReport the number of whole years from date of birth to the application date.Example: 24Code 8888 = Not applicable Age of Co-Applicant or Co-BorrowerApplicationReport the number of whole years from date of birth to the application date.Example: 24Code 8888 = Not applicableCode 9999 = No Co-ApplicantIncomeApplicationIncome VerificationTax ReturnsPay StubsFinancial StatementsIncome Calculation WorksheetEnter the gross annual income you relied on in making the credit decision.Example: 36 or NAEnter “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 consideredActual distributions from retirement accounts and other assets that you rely on as income should be reported as income.Type of PurchaserFile documentationInvestor agreement Not applicablee.g. denied, withdrawn, approved not accepted, closed for incompletenessFannie MaeGinnie MaeFreddie MacFarmer MacPrivate securitizerCommercial bank, savings bank or savings association71. Credit union, mortgage company or finance company72. Life insurance company8. Affiliate institution9. Other type of purchaserRate SpreadFFIEC Rate Spread CalculatorReport the rate spread for ALL transactions subject to Regulation Z, not just those over the HPML threshold.Example: 0.428 or NAReport “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 StatusHOEPA Testing WorksheetHigh-cost mortgageNot a high-cost mortgageNot applicableLien StatusDeedTitleApplicationSecured by a 1st lienSecured by a subordinate lienReport 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 ScoresReport the credit score(s) relied on in making the credit decision even if it was not a 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 actually used.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 BorrowerCredit ReportExample: 650Code 7777 = Credit score not availableCode 8888 = Not applicableCredit Score of Co-Applicant or Co-BorrowerCredit ReportExample: 650Code 7777 = Credit score not availableCode 8888 = Not applicableCode 9999 = No Co-ApplicantApplicant or Borrower, Name & Version of Credit Scoring ModelScoring modelEquifax Beacon 5.0Experian Fair IsaacFICO Risk Score Classic 04FICO Risk Score Classic 98VantageScore 2.0VantageScore 3.0More than one credit scoring model Other credit scoring modelNot applicableIf 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 ModelScoring modelEquifax Beacon 5.0Experian Fair IsaacFICO Risk Score Classic 04FICO Risk Score Classic 98VantageScore 2.0VantageScore 3.0More than one credit scoring model Other credit scoring modelNot applicableNo Co-ApplicantIf 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 DenialFile DocumentationAdverse Action NoticeDebt-to-Income ratioIncome insufficient for amount of credit requested, excessive obligations in relation to incomeEmployment historyTemporary or irregular employment, length of employmentCredit historyInsufficient # credit references, unacceptable credit references, no credit, limited credit, poor credit, etc.CollateralValue or type of collateral insufficientInsufficient cash (e.g. downpayment, closing costs, etc.)Unverifiable informationUnable to verify credit experience, unable to verify employment, unable to verify incomeCredit application incompleteMortgage insurance deniedOtherLength at residence, temporary residences, or otherNot applicableEnter as many as 4 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 CostsClosing DisclosureExample: 2399.04 or NARefer to Total Loan Costs, Total Borrower-Paid Origination Charges, Total Points and Fees and Lender Credits.Total Points and FeesClosing DisclosureExample: 2399.04 or NARefer to Total Points and Fees.Origination ChargesClosing DisclosureExample: 2399.04 or NARefer to Total Borrower-Paid Origination Charges.Discount Points Closing DisclosureExample: 2399.04 or NAReport Total Discount Points Paid.If no points were paid, leave this field blank.Lender CreditsClosing DisclosureExample: 1500.24 or NARefer to Lender Credits Issued.If no lender credits were provided, leave this field blank.Interest RateNoteExample 4.125 or NAReport 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 TermNoteUnderwriting DocumentExample: 24 or NADebt-to-Income RatioUnderwriting DocumentationExample: 42.95 or NACombined Loan-to-Value RatioUnderwriting DocumentationExample 80.05 or NAYou 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 TermNoteExample: 360 or NAReport 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 PeriodTRID DisclosuresHome Equity Loan Agreement and DisclosureExample: 24 or NAReport 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 PaymentNoteBalloon PaymentNo Balloon PaymentInterest-Only PaymentsTRID DisclosuresHome Equity Loan Agreement and DisclosureInterest-only paymentsNo interest-only paymentsNegative AmortizationTRID DisclosuresHome Equity Loan Agreement and DisclosureNegative amortizationNo negative amortizationOther non-Amortizing FeaturesTRID DisclosuresHome Equity Loan Agreement and DisclosureOther non-fully amortizing featuresNo other non-fully amortizing featuresProperty ValueAppraisal or EvaluationExample: 350500 or NAField is not rounded.Report “NA” if not decision was made, even if you obtained a property value (e.g. withdrawn, closed for incompleteness).Manufactured Home Secured Property TypeAppraisalManufactured home and landManufactured home and not landNot applicableManufactured Home Land Property InterestAppraisalDirect ownershipIndirect ownershipPaid leaseholdUnpaid leaseholdNot applicableTotal UnitsAppraisalExample: 5Multifamily Affordable UnitsInformation provided by the applicantProperty valuation or inspectionPublic recordsExample: 5 or NAReport the number of individuals dwelling units that are income-restricted pursuant to Federal, State or local affordable housing programs.Submission of ApplicationMLO is an employee of your institutionThird party agentSubmitted directly to your institutionNot submitted directly to your institutionNot applicableInitially Payable to your InstitutionNote or loan contractInitially payable to your institutionNot initially payable to your institutionNot applicableMortgage Loan Originator NMLSR IdentifierMLO ListingNMLS Consumer Access SiteExample: 123450 or NAIf the loan officer does not have an NMLS # (e.g. commercial), enter “NA”Automated Underwriting SystemUnderwriting systems usedDesktop Underwritrer (DU)Loan Prospector (LP)Technology Open to Approved Lenders (TOTAL) ScorecardGuaranteed Underwriting System (GUS)OtherNot applicableEnter 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 ResultResults provided from systemApprove/EligibleApprove/IneligibleRefer/EligibleRefer/IneligibleRefer with CautionOut of ScopeErrorAcceptCautionIneligibleIncompleteInvalidReferEligibleUnable to DetermineOtherNot applicableEnter 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 MortgageNoteReverse mortgageNot a reverse mortgageOpen-End Line of CreditNoteOpen-end line of creditNot an open-end line of creditBusiness of Commercial PurposeCredit approval memoPrimarily for business or commercial purposeNot primarily for business or commercial purpose ................
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