HMDA Flashcards

Question

What is a dwelling and how does it factor into covered loans?

Answer 1

A loan is not a closed-end mortgage loan and a line of credit is not an open-end line of credit unless it is secured by a lien on a dwelling. A dwelling is a residential structure. There is no requirement that the structure be attached to real property or that it be the applicant’s or borrower’s residence.

Answer 2

1. Principal residences; 2. Second homes and vacation homes; 3. Investment properties; 4. Residential structures whether or not attached to real property; 5. Detached residential structures; 6. Individual condominium and cooperative units; 7. Manufactured homes or other factory-built homes; and 8. Multifamily residential structures or communities, such as apartment buildings, condominium complexes, cooperative buildings or housing complexes, and manufactured home communities.

Answer 3

Yes, A dwelling is not limited to a structure that has four or fewer units. It also includes a multifamily dwelling, which is a dwelling that includes five or more individual dwelling units. A multifamily dwelling includes a manufactured home community.

Answer 4

Yes, a loan related to a manufactured home community is secured by a dwelling even if it is not secured by any individual manufactured homes, but is secured only by the land that constitutes the manufactured home community.

Answer 5

This is not secured by a dwelling. a loan related to a multifamily residential structure or community other than a manufactured home community is not secured by a dwelling unless it is secured by one or more individual dwelling units.

Answer 6

No, the covered loan is not secured by a multifamily dwelling as a covered loan secured by 5 or more separate dwellings, which are not multifamily dwellings in more than one location is a not a loan secured by a multifamily dwelling.

Answer 7

The covered loan would not be secured by a multifamily dwelling, as a covered loan secured by five or more separate dwelling that are located within a multifamily dwelling, but which is not secured by the ENTIRE multifamily dwelling is not secured by a multifamily dwelling as defined by HMDA.

Answer 8

1. Recreational vehicles, such as boats, campers, travel trailers, or park model recreational vehicles; 2. Houseboats, floating homes, or mobile homes constructed before June 15, 1976; 3. Transitory residences, such as hotels, hospitals, college dormitories, or recreational vehicle parks; and 4. Structures originally designed as a dwelling but used exclusively for commercial purposes, such as a home converted to a daycare facility or professional office.

Answer 9

Its depends. It is a dwelling if the property's primary use is residential. If the property's primary use is commercial it is not a dwelling

Answer 10

It is a dwelling. However, transitory residences used to provide such services are not dwellings. Properties used to provide medical care, such as skilled nursing, rehabilitation, or long-term medical care, are not dwellings. If a property is used for long-term housing, to provide related services (such as assisted living), and to provide medical care, the property is a dwelling if its primary use is residential.

Answer 11

A financial institution may use any reasonable standard to determine a property’s primary use, such as square footage, income generated, or number of beds or units allocated for each use. It may select the standard on a case-by-case basis.

Answer 12

1. A closed-end mortgage loan or an open-end line of credit that a financial institution originates or purchases in a fiduciary capacity, such as a closed-end mortgage loan or an open-end line of credit that a financial institution originates or purchases as a trustee. 2. A closed-end mortgage loan or an open-end line of credit secured by a lien on unimproved land. 3. A closed-end mortgage loan or an open-end line of credit that is temporary financing. 4. The purchase of an interest in a pool of closed-end mortgage loans or open-end lines of credit, such as mortgage-participation certificates, mortgage-backed securities, or real estate mortgage investment conduits. 5. The purchase solely of the right to service closed-end mortgage loans or open-end lines of credit. 6. The purchase of a closed-end mortgage loan or an open end line of credit as part of a merger or acquisition or as part of the acquisition of all of a branch office’s assets and liabilities. 7. A closed-end mortgage loan or an open-end line of credit, or an application for a closed-end mortgage loan or open end line of credit, for which the total dollar amount is less than $500. 8. The purchase of a partial interest in a closed-end mortgage loan or an open-end line of credit. 9. A closed-end mortgage loan or an open-end line of credit if the proceeds are used primarily for agricultural purposes or if the closed-end mortgage loan or open-end line of credit is secured by a dwelling that is located on real property that is used primarily for agricultural purposes. 10. A closed-end mortgage loan or an open-end line of credit that is or will be made primarily for business or commercial purposes, unless it is a home improvement loan, a home purchase loan, or a refinancing. 11. A closed-end mortgage loan if the financial institution originated fewer than 100 closed-end mortgage loans in either of the two preceding calendar years. 12. An open-end line of credit if the number of open-end lines of credit that the financial institution originated in either of the two preceding calendar years does not meet or exceed the applicable threshold. (500 or fewer in proceeding two calendar years) 13. A transaction that provided (or, in the case of an application, proposed to provide) new funds to the borrower in advance of being consolidated in a New York CEMA classified as a supplemental mortgage under New York Tax Law Section 255. However, the transaction is excluded only if final action on the consolidation was taken in the same calendar year as the final action on the new funds transaction.

Answer 13

No this is not excluded. Generally, a loan or line of credit must be secured by a dwelling to be a covered loan. Regulation C also lists closed-end mortgage loans and open-end lines of credit secured only by vacant or unimproved land as excluded transactions. However, a loan or line of credit secured by a lien on unimproved land is deemed to be secured by a dwelling (and might not be excluded) if the financial institution knows, based on information that it receives from the applicant or borrower at the time the application is received or the credit decision is made, that the proceeds of that loan or credit line will be used within two years after closing or account opening to construct a dwelling on, or to purchase a dwelling to be placed on, the land.

Answer 14

Yes financing would not be considered temporary (thus excluded) if it is designed to be replaced by a separate permanent financing extended to the same borrower at a later time. The separate permanent financing may be extended by any lender (i.e., by either the lender that extended the temporary financing or another lender). In addition, a construction-only loan or line of credit is considered temporary financing and excluded under Regulation C if the loan or line of credit is extended to a person exclusively to construct a dwelling for sale.

Answer 15

Regulation C directs financial institutions to Regulation Z’s official commentary for guidance on what is an agricultural purpose. Regulation Z’s official commentary states that agricultural purposes include planting, propagating, nurturing, harvesting, catching, storing, exhibiting, marketing, transporting, processing, or manufacturing food, beverages, flowers, trees, livestock, poultry, bees, wildlife, fish, or shellfish by a natural person engaged in farming, fishing, or growing crops, flowers, trees, livestock, poultry, bees, or wildlife. A financial institution may use any reasonable standard to determine the primary use of the property, and may select the standard to apply on a case-by-case basis.

Answer 16

Not all transactions that are primarily for a business purpose are excluded transactions. Thus, a financial institution must collect, record, and report data for dwelling-secured, business-purpose loans and lines of credit that are home improvement loans, home purchase loans, or refinancings if no other exclusion applies. Regulation C provides that, if a closed-end mortgage loan or an open-end line of credit is deemed to be primarily for a business, commercial, or organizational purpose under Regulation Z, 12 CFR 1026.3(a) and its official commentary, then the loan or line of credit also is deemed to be primarily for a business or commercial purpose.

Answer 17

A financial institution may report applications for, originations of, and purchases of closed-end mortgage loans that are excluded transactions under 12 CFR 1003.3(c)(11). However, a financial institution that chooses to report such excluded applications, originations, and purchases must report all such applications it received for closed-end mortgage loans, all closed-end mortgage loans it originates, and all closed end mortgage loans it purchases that would otherwise be covered loans for a given calendar year. Regulation B permits a financial institution to collect information regarding the ethnicity, race, and sex of an applicant for a closed-end mortgage loan that is an excluded transaction under 12 CFR 1003.3(c)(11), if the financial institution submits HMDA data concerning such closed-end mortgage loans and applications or if it submitted such HMDA data for any of the preceding five calendar years.

Answer 18

Yes, but must report all applications for otherwise covered open-end lines of credit that it receives, all otherwise covered open-end lines of credit it originates, and all otherwise covered open-end lines of credit it purchases that would otherwise be covered loans for a given calendar year. Regulation B permits a financial institution to collect information regarding the ethnicity, race, and sex of an applicant for an open-end line of credit that is an excluded transaction under 12 CFR 1003.3(c)(12), if it submits HMDA data concerning such open-end lines of credit and applications or if it submitted such HMDA data for any of the preceding five calendar years.

Answer 19

Yes, the transaction is excluded only if final action on the consolidation was taken in the same calendar year as the final action on the new funds transaction. Additionally, the transaction is excluded only if, at the time that it originated the transaction providing the new funds, the financial institution intended to consolidate the loan into a New York CEMA. This exclusion does not apply to similar preliminary transactions that are consolidated pursuant to laws other than New York Tax Law Section 255. Such preliminary transactions under other laws must be reported if they are covered loans and are not covered by another exclusion. New funds provided in advance of being consolidated into a New York CEMA classified as a supplemental mortgage under New York Tax Law Section 255 are reported only insofar as they form part of the total amount of the reported New York CEMA. They are not reported as a separate amount. If a New York CEMA that consolidates an excluded preliminary transaction is carried out in a transaction involving an assumption, the financial institution reports the New York CEMA and does not report the preliminary transaction separately.

Answer 20

It must determine whether it has engaged in activity that obligates it to report information about the transaction. Generally, a financial institution is required to report information for actions taken on applications (as that term is defined below) for covered loans, originations of covered loans, and purchases of covered loans. If a financial institution receives an application and that application results in the financial institution originating a covered loan, the financial institution reports the origination of the covered loan, and does not separately report the application.

Answer 21

- Applications - Originations and Purchases of Covered Loans - Transactions involving Multiple Entities - Transactions with Partial exemptions

Answer 22

An application is: - an oral or written request - for a covered loan - that is made in accordance with procedures the financial institution uses for the type of credit requested. This definition of application is similar to the Regulation B definition, except that prequalification requests are not applications under Regulation C. Interpretations that appear in the official commentary to Regulation B are generally applicable to the definition of application under Regulation C, except for those interpretations that include a prequalification request within the definition of application.

Answer 23

It depends. Under Regulation C, a request for a preapproval may be treated differently than a request for a prequalification for certain types of loans. The determination of whether a request is a prequalification request (which is not an application) or a preapproval request (which might be an application) is based on Regulation C, not on the labels that a financial institution uses or interpretations of other regulations, such as Regulation B. A preapproval request is an application under Regulation C if the request is: 1. For a home purchase loan; 2. Not secured by a multifamily dwelling; 3. Not for an open-end line of credit or for a reverse mortgage; and 4. Reviewed under a preapproval program (see definition of preapproval program)

Answer 24

A preapproval program for purposes of Regulation C is a program in which the financial institution: 1. Conducts a comprehensive analysis of the applicant’s creditworthiness (including income verification), resources, and other matters typically reviewed as part of the financial institution’s normal credit evaluation program; and then 2. Issues a written commitment that: (a) is for a home purchase loan; (b) is valid for a designated period of time and up to a specified amount; and (c) is subject only to specifically permitted conditions.

Answer 25

The written commitment issued as part of the preapproval program can be subject to only the following types of conditions: 1. Conditions that require the identification of a suitable property; 2. Conditions that require that no material change occur regarding the applicant’s financial condition or creditworthiness prior to closing; and 3. Limited conditions that (a) are not related to the applicant’s financial condition or creditworthiness and (b) the financial institution ordinarily attaches to a traditional home mortgage application. Examples of conditions ordinarily attached to a traditional home mortgage application include requiring an acceptable title insurance binder or a certificate indicating clear termite inspection sale of the applicant’s present home to purchase a new home, a settlement statement showing adequate proceeds from the sale of the present home.

Answer 26

No. If a financial institution does not regularly use procedures to consider requests but instead considers requests on an ad hoc basis, the financial institution is not required to treat the ad hoc requests as having been reviewed under a preapproval program. However, a financial institution should be generally consistent in following uniform procedures for considering such ad hoc requests.

Answer 27

Under Regulation C, a financial institution must collect, record, and report data regarding an application it receives if: (1) the application did not result in the financial institution originating a covered loan; and (2) the financial institution took action on the application or the applicant withdrew the application while the financial institution was reviewing it.

Answer 28

If the application results in the financial institution originating a covered loan, the financial institution reports the covered loan, not the application itself. Otherwise it would be reported as an application.

Answer 29

Although requests under preapproval programs are applications, a financial institution reports data regarding a request under a preapproval program only if the preapproval request is denied or approved but not accepted. A financial institution will also report a request under a preapproval program that results in the financial institution originating a home purchase loan, but it will be reported as an originated covered loan.

Answer 30

On the HMDA LAR for the calendar year during which it takes action even if the bank received the application in the previous calendar year.

Answer 31

Yes. A purchase includes a repurchase of a covered loan, regardless of whether the financial institution chose to repurchase the covered loan or was required to repurchase it because of a contractual obligation, and regardless of whether the repurchase occurred within the same calendar year that the covered loan was originated or in a different calendar year.

Answer 32

No. A purchase does not include a temporary transfer of a covered loan to an interim funder or warehouse creditor as part of an interim funding agreement under which the financial institution that originated the covered loan is obligated to repurchase it for sale to a subsequent investor. Such funding agreements are often referred to as repurchase agreements and are sometimes used as the functional equivalents of warehouse lines of credit.

Answer 33

Only one financial institution reports the origination of a covered loan. If more than one institution is involved in the origination of a covered loan, the institution that makes the credit decision approving the application before loan closing or account opening is responsible for reporting the origination of the covered loan. It is not relevant whether the loan closed in the reporting financial institution’s name. If more than one institution approved an application prior to loan closing or account opening and one of those institutions purchased the covered loan after closing or account opening, the institution that purchased the covered loan after closing or account opening is responsible for reporting the origination of the covered loan.

Answer 34

In the case of an application that did not result in an origination, a financial institution reports the action it took on that application if it made a credit decision on the application or was reviewing the application when the application was withdrawn or closed for incompleteness. The financial institution is also required to report the application if the financial institution was reviewing the application when it was withdrawn or the file was closed for incompleteness.

Answer 35

If a financial institution makes a credit decision on a covered loan or application through the actions of an agent, the financial institution reports the covered loan or application. State law determines whether one party is the agent of another party.

Answer 36

This means the bank is not required to collect, record, and report specific data points.

Answer 37

- must be an insured depository institution or credit union - must not have received a less than satisfactory rating on its two most recent CRA PE ratings as of Dec 31 of the preceding year (overall needs or substantial noncompliance) A financial institution that does not satisfy either the definition of an “insured credit union” or an “insured depository institution” may not rely on either of the partial exemptions, even if it satisfies the loan-volume thresholds. Similarly, an insured depository institution that does not satisfy the criteria regarding CRA examination history cannot rely on either of the partial exemptions.

Answer 38

Each of the partial exemptions applies only to certain covered loans and applications and only if an applicable loan-volume threshold is met. An insured depository institution or insured credit union: (1) must meet the applicable loan-volume threshold for closed-end mortgage loans in order for a partial exemption to apply to its closed-end mortgage loan transactions; and (2) Must meet the applicable loan-volume threshold for open-end lines of credit in order for a partial exemption to apply to its open-end line of credit transactions.

Answer 39

22 data points | 26 data points

Answer 40

A partial exemption applies to an eligible financial institution’s applications for, originations of, and purchases of closed-end mortgage loans if the institution originated fewer than 500 closed-end mortgage loans in each of the two preceding calendar years. Similar to other data collection and reporting, the bank would only count covered loans.

Answer 41

A partial exemption applies to an eligible financial institution’s applications for, originations of, and purchases of open-end lines of credit if the institution originated fewer than 500 open-end lines of credit in each of the two preceding calendar years. However, a financial institution is not required to collect or report any information for open-end lines of credit if the institution originated fewer than 500 open-end lines of credit during either of the two preceding calendar years. This is because open-end lines of credit are excluded transactions for a financial institution that originated fewer than 500 open end lines of credit during either of the two preceding calendar years.

Answer 42

• Universal Loan Identifier (ULI) (1003.4(a)(1)(i)) If a bank does not report ULI it must report a non-universal loan identifier. • Application Channel (1003.4(a)(33)) • Loan Term (1003.4(a)(25)) • Reasons for Denial (1003.4(a)(16)17 • Property Address (1003.4(a)(9)(i)) • Manufactured Home Secured Property Type (1003.4(a)(29)) • Manufactured Home Land Property Interest (1003.4(a)(30)) • Property Value (1003.4(a)(28)) • Multifamily Affordable Units (1003.4(a)(32)) • Debt-to-Income Ratio (1003.4(a)(23)) • Combined Loan-to-Value Ratio (1003.4(a)(24)) • Credit Score (1003.4(a)(15)) • Automated Underwriting System (1003.4(a)(35)) • Interest Rate (1003.4(a)(21)) • Introductory Rate Period (1003.4(a)(26)) • Rate Spread (1003.4(a)(12)) • Non-Amortizing Features (1003.4(a)(27)) • Total Loan Costs or Total Points and Fees (1003.4(a)(17)) • Origination Charges (1003.4(a)(18)) • Discount Points (1003.4(a)(19)) • Lender Credits (1003.4(a)(20)) • Prepayment Penalty Term (1003.4(a)(22)) • Reverse Mortgage Flag (1003.4(a)(36)) • Open-End Line of Credit Flag (1003.4(a)(37)) • Business or Commercial Purpose Flag (1003.4(a)(38)) • Mortgage Loan Originator Identifier (1003.4(a)(34))

Answer 43

False. A bank can still choose to collect a report all exempt data points even if covered by a partial exemption.

Answer 44

Property address, credit score, reasons for denial, total loan costs or total points and fees, non-amortizing features, application channel, and automated underwriting system have multiple data fields. If a financial institution opts to report a data point with multiple fields, it must report all of the data fields that make up that data point.

Answer 45

Either exempt or NA.

Answer 46

* Ethnicity (1003.4(a)(10)(i)) * Race (1003.4(a)(10)(i)) * Sex (1003.4(a)(10)(i)) * Age (1003.4(a)(10)(ii)) * Income (1003.4(a)(10)(iii)) * Legal Entity Identifier (LEI) (1003.5(a)(3)) * Application Date (1003.4(a)(1)(ii) * Preapproval (1003.4(a)(4)) * Loan Type (1003.4(a)(2)) * Loan Purpose (1003.4(a)(3)) * Loan Amount (1003.4(a)(7)) * Action Taken (1003.4(a)(8)(i)) * Action Taken Date (1003.4(a)(8)(ii)) * State (1003.4(a)(9)(ii)(A)) * County (1003.4(a)(9)(ii)(B)) * Census Tract (1003.4(a)(9)(ii)(C)) * Construction Method (1003.4(a)(5)) * Occupancy Type (1003.4(a)(6) * Lien Status (1003.4(a)(14)) * Number of Units (1003.4(a)(31)) * HOEPA Status (1003.4(a)(13)) * Type of Purchaser (1003.4(a)(11))

Answer 47

Each data point may correspond to more than one field reported on the HMDA LAR. Accordingly there are 48 data points described in Regulation C and 110 fields reported on the HMDA LAR. One example of a data point that corresponds to multiple fields is the ethnicity data point. Each applicant and co-applicant may enter up to five ethnicities on their application.

Answer 48

Regulation C requires a financial institution to record the data about a covered loan or application on a HMDA LAR within 30 calendar days after the end of the calendar quarter in which the financial institution takes final action on the covered loan or application. A financial institution is not required to record all of its HMDA data for a quarter on a single HMDA LAR. Rather, a financial institution may record data on a single HMDA LAR or may record data on one or more HMDA LARs for different branches or different loan types (such as home purchase loans or home improvement loans or loans on multifamily dwellings). Other regulations may require more frequent recording. Quarterly records can be maintained in any format as long as they are available upon request.

Answer 49

1. Its name; 2. The calendar year and, effective January 1, 2020, if applicable, the calendar quarter to which the data relate (see 12 CFR 1003.5(a)(1)(ii)20 for information on quarterly reporting); 3. The name and contact information for a person who can be contacted with questions about the submission; 4. The financial institution’s appropriate Federal agency; 5. The total number of entries in the submission; 6. The financial institution’s Federal Taxpayer Identification Number (TIN); and 7. The financial institution’s Legal Entity Identifier (LEI).

Answer 50

A financial institution that is a subsidiary of a bank or savings association must complete its own HMDA LAR and submit it, directly or through its parent, to the appropriate Federal agency for the subsidiary’s parent. 12 CFR 1003.5(a)(2). A financial institution is a subsidiary of a bank or savings association (for purposes of reporting HMDA data to the same agency as the parent) if the bank or savings association holds or controls an ownership interest in the financial institution that is greater than 50 percent.

Answer 51

Under Regulation C, a financial institution must submit its annual HMDA LAR in electronic format to its appropriate Federal supervisory agency by March 1 of the year following the calendar year for which the data are collected.

Answer 52

A financial institution must retain a copy of its submitted annual HMDA LAR for at least three years. Financial institutions may retain their annual HMDA LARs in either paper or electronic form.

Answer 53

The HMDA Rule requires some financial institutions to report data on a quarterly basis as well as on an annual basis. The quarterly reporting requirement is effective January 1, 2020. It applies to a financial institution that reported at least 60,000 originated covered loans and applications (combined) for the preceding calendar year. The financial institution does not count purchased covered loans when determining whether the quarterly reporting requirement applies. If quarterly reporting is required, the financial institution must report all data required to be recorded for the calendar quarter within 60 calendar days after the end of the calendar quarter. The quarterly reporting requirement does not apply, however, to the fourth quarter of the year. the quarterly reporting requirement reports its fourth quarter data as part of its annual submission. In its annual submission, a quarterly reporter will resubmit the data previously submitted for the first three calendar quarters of the year, including any corrections to the data, as well as its fourth quarter data.

Answer 54

- Under Regulation C, the FFIEC shall provide a notice to the financial institution that the financial institution’s disclosure statement (aggregated data derived from loan-level data submitted for the prior calendar year) is available. - No later than three business days (any calendar day other than a Saturday, Sunday, or legal public holiday) after receiving notice from the FFIEC, the financial institution must make available to the public, upon request, a written notice that clearly conveys that the financial institution’s disclosure statement may be obtained on the Bureau’s website. - A financial institution must make the notice available to the public for a period of five years. - At its discretion, a financial institution may also provide its disclosure statement and impose a reasonable fee for costs incurred reproducing or providing the statement. Even if it provides the disclosure statement, a financial institution must comply with the notice requirement.

Answer 55

-Upon request from a member of the public, a financial institution must provide a written notice regarding the availability of its modified HMDA LAR (the financial institution’s HMDA LAR, as modified by the Bureau to protect applicant and borrower privacy). The written notice must clearly convey that the financial institution’s HMDA LAR, as modified by the Bureau to protect borrower and applicant privacy, may be obtained on the Bureau’s website. - The notice must be made available in the calendar year following the calendar year for which the financial institution collected data. The notice must be made available for three years. - At its discretion, a financial institution may also provide its HMDA LAR, as modified by the Bureau, and impose a reasonable fee for any costs incurred to reproduce or provide the data. Even if it decides to provide the modified HMDA LAR, a financial institution must comply with the notice requirement.

Answer 56

The notice must be made available for three years. For data that it was required to collect in 2018, a financial institution must make available a notice through calendar year 2021 that its modified HMDA 2018 LAR is available.

Answer 57

A financial institution must post, in the lobby of its home office and each branch office physically located in an MSA or Metropolitan Division (MD), a general notice about the availability of its HMDA data on the Bureau’s website. A financial institution may, but is not required to, use the sample notice in comment 5(e)-1 to the regulation to satisfy this requirement. In any case, the notice must clearly convey that the financial institution’s HMDA data are available on the Bureau’s website.

Answer 58

No this is not a violation.

Answer 59

False. A bank is responsible for ensuring the accuracy of third party reporting.

Answer 60

This is deemed a bona fide error and is not a violation.

Answer 61

The error or omission is not a violation of HMDA or Regulation C, provided that the institution corrects or completes the information prior to submitting the loan/application register to its regulatory agencies.

Answer 62

A violation of Regulation C is subject to administrative sanctions, including civil money penalties. Compliance can be enforced by the Bureau, the U.S. Department of Housing and Urban Development, the FDIC, the FRB, the National Credit Union Administration, or the Office of the Comptroller of Currency.

Answer 63

2020-2021 the bank would need to have originated 500 open end lines of credit in the preceding two calendar years. 2020 the bank would need to have originated 200 open end lines of credit in the preceding two calendar years.

Answer 64

2020-2021 originate 100 Closed end mortgage loans in each of the two preceding calendar years. Prior to 2020 it was 25 originated loans in the the past two years.

Answer 65

- Select a random sample of entries from the HMDA LAR (based on the sample table and the total number of entries) and ask the bank to provide loan files for validation. There should be both an initial sample and a total sample selected. - if a bank's data is collected from multiple different systems, examiners may test a single sample from the entire HMDA LAR, or test samples from selected systems based on risk - all data fields may be reviewed or depending on the agency certain designated fields can be prioritized. - verify accuracy of data in the initial LAR sample against data from the loan/application files. Differences that are not adequately explained should be documented as errors. - If the number of errors in any data field reviewed equals or exceeds the Initial Sample Threshold in the HMDA table, examiners should review the remainder of the Total Sample. -With the total sample, examiners must review all data fields that had one or more errors in the Initial Sample and may review any or all Initial Sample data fields reviewed and found to have no errors previously. -After reviewing the total sample, if the total number of errors in any data field equals or exceeds the resubmission threshold in column D of the HMDA table, examiners should direct the bank to correct any such data field in its full HMDA LAR and resubmit with the corrected data (scrub).

Answer 66

True. If examiners have a reasonable basis to believe that errors in that field or fields will likely make analysis of the HMDA data unreliable. To illustrate, assume examiners discover that a financial institution has incorrectly coded withdrawn applications as denials to such an extent that it likely prevents reliable analysis of underwriting disparities in a fair lending examination. Examiners may direct a financial institution to correct the Action Taken data field and resubmit the HMDA LAR even if the number of Action Taken errors found in the Total Sample does not equal or exceed the Resubmission Threshold in column D of the HMDA table.

Answer 67

Examiners should not count the following differences between data in the HMDA LAR and in the loan files as errors: * Three calendar days or less in the date the application was received or the date shown on the application form reported. * One thousand dollars or less in the amount of the covered loan or the amount applied for. * Three calendar days or less in the date of the action taken by the financial institution reported. Provided that such differences do not result in reporting data for the wrong calendar year; and * Rounding errors in reporting the dollar amount, rounded to the nearest thousand, of the gross annual income relied on in making the credit decision or, if a credit decision was not made, the gross annual income relied on in processing the application.

Answer 68

Would not be counted as an error because it is within three calendar days of June 4, which means it means a tolerance.

Answer 69

A HMDA LAR application date of May 31 or June 8 would be counted as an error because it is more than three calendar days from June 4. Does not meet the tolerance.

Answer 70

A group of FIG fields as follows: • The Ethnicity of Applicant or Borrower data field group: comprised of six FIG fields with information on an applicant’s or borrower’s ethnicity (FIG Data Field Numbers 19-24); • The Ethnicity of Co-Applicant or Co-Borrower data field group: comprised of six FIG fields with information on a co-applicant’s or co-borrower’s ethnicity (FIG Data Field Numbers 25-30); • The Race of Applicant or Borrower data field group: comprised of eight FIG fields with information on an applicant’s or borrower’s race (FIG Data Field Numbers 33-40); and • The Race of Co-Applicant or Co-Borrower data field group: comprised of eight FIG fields with information on a co-applicant’s or co-borrower’s race (FIG Data Field Numbers 41-48).

Answer 71

The bank reports the information in two FIG fields Ethnicity of applicant or Borrower 1 (1:Hispanic or Latino) and Ethnicity of Applicant or Borrower 2 (11: Mexican)

Answer 72

Initial sample is 15. two errors in the action taken data field equals the initial sample threshold so examiners would expand and review the remaining loans in the total sample. The additional error in the total sample brings the action taken field to 3 errors which meets the threshold for resubmission. Examiners direct the bank to scrub the action taken field and resubmit the HMDA LAR.

Answer 73

47 loans total sample 29 loans initial sample

Answer 74

Neither error meets the threshold for expansion to the total sample. Therefore, examiners end the HMDA transaction testing for Financial Institution B and do not proceed to Stage 2 testing of the 18 remaining entries in the Total Sample because no Stage 1 errors in any single data field equaled or exceeded the Initial Sample Threshold.

Answer 75

Total sample: 159 loans | initial sample: 61 loans

Answer 76

Examiners should expand the sample and test the remaining 98 entries. The additional findings bring the action taken data field to 4 errors total and the loan amount data field to 10 errors total. Additionally we have four errors in the CT field. All errors exceed the resubmission threshold. Therefore, Financial Institution C is directed to correct the Action Taken data field, the Loan Amount data field, and the Census Tract data field and resubmit its HMDA LAR with those fields corrected.

Answer 77

Examiners identified a total of two errors in the Race of Applicant or Borrower data field group in the initial sample so they need to expand to the total sample. In the remaining 44 loans in the total sample examiners identified a total of four loans with at least one error in one of the eight Race of Applicant or Borrower FIG fields, which equals the resubmission threshold. Therefore, Financial Institution D is directed to correct all eight FIG fields in the Race of Applicant or Borrower data field group and resubmit its HMDA LAR with those FIG fields corrected.

Answer 78

ensure the following: 1. appropriate collection, recording, and reporting of data on applications for covered loans that it receives, covered loans that it originates, and covered loans that it purchases pursuant to HMDA and Regulation C requirements; and 2. compliance with HMDA and Regulation C’s disclosure requirements

Answer 79

1. An institution annually or more frequently, conducts analysis to determine whether it must collect, record, and report data regarding dwelling secured applications and loans (covered transactions) pursuant to HMDA. 2. An institution conducts analysis to ensure that all reportable applications and loans are collected and recorded on the HMDA LAR. 3. An institution has assigned one or more individuals responsibility for the oversight of HMDA compliance, including HMDA data collection, recording, and reporting. 4. An institution has ensured individuals responsible for HMDA compliance receive access to and appropriate training on HMDA, Regulation C and its commentary, all applicable regulatory and statutory changes, the Filing Instructions Guide, the Guide to HMDA Reporting: Getting It Right!, and any other relevant materials. 5. The Board of Directors and management possess sufficient knowledge to ensure oversight of compliance with HMDA and Regulation C. 6. The Board of Directors and management provide appropriate resources and oversight regarding ensuring an institution’s compliance with HMDA and Regulation C. 7. An institution takes effective corrective action in response to identified HMDA deficiencies. 8. Management and, if appropriate, the Board of Directors reviews policies and procedures, monitoring and/or audit, and compliance reports regarding the institution’s HMDA data reporting, commensurate with its HMDA risk profile.

Answer 80

9. The individuals responsible for ensuring HMDA compliance possess an adequate level of knowledge regarding HMDA and Regulation C, including all applicable statutory and regulatory changes. 10. An institution has developed appropriate policies and procedures, and revised those policies and procedures as necessary, to ensure HMDA compliance. 11. HMDA data are collected at all branches (if applicable), and, if so, whether relevant branch personnel are appropriately trained on HMDA data collection, recording, and reporting requirements. 12. An institution’s loan officers, including the commercial loan department, who may handle HMDA- reportable applications, are informed of collection, recording, and reporting requirements. 13. An institution has policies and procedures to ensure continuing HMDA compliance during and after major changes in an institution’s business or structure. 14. An institution has established internal review procedures, monitoring, and/or audit schedules, depending on the circumstances, that comprehensively cover all pertinent HMDA and Regulation C requirements, including all applicable statutory and regulatory changes since prior compliance reviews and/or audits. 15. An institution conducts compliance reviews and/or audits, as appropriate, that include a sufficient level of transactional analysis as well as written reports that detail findings and recommendations for corrective action. Also, determine whether the Board of Directors and management are informed of these findings and recommendations. 16. An institution adequately monitors vendors and other third-party service providers that perform functions or deliver services related to HMDA data collection, recording, and reporting.

Answer 81

FDIC HMDA reporters are divided into one of the following two size categories: financial institutions with 500 or more LAR lines, and financial institutions with fewer than 500 total LAR lines.

Answer 82

Examination staff will conduct transaction testing for accuracy and completeness in advance of the on-site portion of the consumer compliance examination. This approach allows an institution to resolve data errors, if any, so the examination can proceed without significant delay.

Answer 83

Examination staff will conduct transaction testing for accuracy and completeness during the on-site portion of the consumer compliance examination, unless testing in advance of the on-site portion promotes examination efficiencies and effectiveness. For example, there may be risk indicators from an institution’s previous HMDA review(s), such as a history of significant HMDA-related CMS deficiencies or Level 2 (Medium Severity) or Level 3 (High Severity) violations that required corrective actions related to HMDA. The risk indicators could serve as a red flag signaling that an extended period of time or additional resources may be required to conduct HMDA validation at an institution. Consequently, transaction testing in advance of the on-site portion of the examination would promote examination efficiencies and effectiveness.

Answer 84

Information Packet Entry Letter

Answer 85

In such cases, examination staff will confirm the errors through discussion with bank management. If examination staff determines that systemic errors likely will make analysis of the HMDA data unreliable, examination transaction testing should not be completed until bank management has ensured that the errors are addressed. Once the LAR data is corrected, examination staff will complete transaction testing in accordance with the FFIEC Testing Guidelines and these Instructions.

Answer 86

In general for each HMDA reporter, examiner will initially review the LAR reported as final for the prior full calendar year. If any errors identified in that review trigger resubmission, examination staff will determine through discussions with management if the root cause of the errors would impact LARs submitted for earlier years. If the root cause of errors in each such data field is systemic across prior years, examination staff may request that bank management correct and resubmit additional years’ LARs, as appropriate, without additional transaction testing. However, if examination staff determines that the root cause of systemic errors in the prior year’s LAR did not impact LARs from earlier years for any such data field, examination staff may determine that testing LARs from additional years is unnecessary. If the root cause of errors in one or more of the data fields for which resubmission is triggered does not appear to be systemic, or if examination staff is unable to determine the root cause of the errors in any such data field, examination staff will determine whether it is necessary to test additional years’ LARs. Examination staff will make this determination in consultation with FDIC field territory management.

Answer 87

An insured depository institution (IDI) eligible for a partial exemption from HMDA reporting may report an exemption code for data fields associated with exempt data points or may report such data fields voluntarily. If an IDI is eligible for a partial exemption with respect to a particular data point, examination staff will validate data fields associated with that data point as part of the HMDA data validation process but will not require resubmission of, or cite a violation in connection with, those data fields.

Answer 88

False: FDIC examination staff generally will review the key data fields rather than all 110 data fields.

Answer 89

- Fair lending review established a focal point and non key data fields are needed for analysis. Transaction testing is limited to the non key data fields. Examiners will validate these fields prior to a comparative file review, but after selecting a focal point. (fields identified based on criteria interview) - Census tract errors. If errors are identified in this key field, examiners may need to review the non-key data fields related to property address. Even if non-key data fields are incorrect, only errors in the CT field are counted as errors.

Answer 90

True: Upon completing a review of non-key data fields, if examination staff determines the data to be unreliable, examination staff will then assess the extent to which the impact of the errors is significant. Examination staff will direct an institution to correct errors in non-key data fields that would affect a consumer compliance examination, including fair lending reviews, or the accuracy of a CRA performance evaluation. Also, in consultation with FDIC field territory management, examination staff may direct an institution to resubmit its HMDA LAR to ensure accurate aggregate data is maintained.

Answer 91

If, during the accuracy review of key data fields, examination staff identifies transactions reported on the LAR that do not meet the regulatory definition of a covered transaction and were reported in error, those transactions are considered overreported transactions. Examination staff will not include data fields from over-reported transactions when counting the number of key data field errors. Rather, examination staff will remove over-reported transactions from the sample universe and replace them with reportable transactions. Nevertheless, examination staff will attempt to determine the root cause of over-reported transactions identified during transaction testing, such as a misunderstanding of the provisions of Regulation C related to business-purpose transactions. Examination staff will address over-reporting errors identified during transaction testing following the procedures to address systemic errors identified before transaction testing.

Answer 92

No, FDIC examination staff will limit review in stage 2 (total sample review) to data fields in which one or more errors were found in stage one (initial sample)

Answer 93

False: Banks can be directed to do this to ensure the LAR supports the use of HMDA data in FL and CRA reviews.

Answer 94

originated or purchased loans and non-originated loan applications (declined, withdrawn, closed for incompleteness, or approved but not accepted) that were not identified as covered transactions.

Answer 95

* Identify departments that take applications for covered loans; * Identify departments, if any, that purchase covered loans; * Identify software systems and tracking reports used within these departments to capture loan application, origination, and purchase data; and * Using the reports from these systems, compile the omissions universe.

Answer 96

* An electronic loan trial balance that includes all loans from the commercial, consumer, and mortgage departments; * Reconciliation or “pipeline” reports showing incoming loan applications; • A list of non- originated applications (if no report or list of non-originated applications is available, examination staff will have to manually compile the universe of non originated loans from the review period); • A list of loans sold, by loan type, if the financial institution sells mortgage loans that are not on the trial balance for the review period; and/or • A list of any dwelling secured loans purchased, by loan type, during the review period.

Answer 97

Targeted Sampling Non targeted Sampling

Answer 98

Targeted Sampling. This is the preferred method because it is most likely to determine whether any applications were omitted. Examination staff will compare the omission universe to all applications reported on the LAR. The two most likely approaches consist of the following: 1) using an omissions universe that consists of one data set, compare all the data in that set against all applications reported on the LAR, or 2) using an omissions universe that consists of multiple data sets, individually compare each of the sets against all applications reported on the LAR. Once examination staff compares the omissions universe to the covered transactions reported on the LAR, any transactions in the omissions universe that are not on the LAR will constitute the targeted omissions universe. Examination staff will use the number of transactions in the targeted omissions universe to determine the omissions sample size using the HMDA Table.

Answer 99

If targeted sampling is not feasible, examination staff will perform non-targeted sampling from among the applications reflected in the reports considered. For example, it may not be feasible to conduct targeted sampling when the available data sets used to create the omissions universe have internal record identifiers that do not correlate to the record identifiers on the LAR. When performing non-targeted sampling, the total number of transactions in the reports considered is the omissions universe and is used to determine the sample size from the HMDA Table. Examination staff then will select a random sample from the omissions universe for review. Some transactions in the omission sample will be reported on the LAR and some will not be reported on the LAR, because the sample was created from a random sample of transactions from the omissions universe.

Answer 100

Examination staff will determine if an application is deemed to have been correctly reported, correctly not reported, or incorrectly reported on the LAR, depending on whether the transaction is for a covered transaction. During the completeness review, examination staff will use the sample sizes and thresholds stated in the HMDA Table. Examination staff will determine whether a transaction was (or was to be) secured by a dwelling and, if so, whether or not is an excluded transaction. The LAR is considered complete if the number of omissions is below the thresholds listed in Column C when testing the Initial Sample or Column D when testing the Total Sample listed in the HMDA Table in Paragraph 11 of the FFIEC Testing Guidelines.

Answer 101

Examination staff will consult with FDIC field territory management to establish a timeline for an institution’s management to correct, review, and verify corrected data. The timeline will take into consideration the nature and complexity of the required data correction, an institution’s resources, and the amount of time required to complete the consumer compliance examination, fair lending review, and/or CRA performance evaluation in a timely manner.

Answer 102

When errors of accuracy or completeness are identified that require correction, examination staff will review the corrections made by an institution once they are completed and before the institution resubmits the data.

Answer 103

Examination staff will conduct revalidation by sampling in accordance with the HMDA Table, based on the size of the institution’s corrected LAR, adjusted to address any identified omissions or over-reporting. If there were accuracy errors, examination staff will focus re-validation of corrections on the key data fields in which errors were identified during transaction testing or on any non-key data fields reviewed as part of a fair lending review or CRA performance evaluation. If there were errors of omission, examination staff will consider the documentation provided by an institution of its corrective actions to ensure the LAR is complete.

Answer 104

If, during the revalidation, examination staff determines that any issues have not been corrected sufficiently and errors remain, examination staff will again instruct an institution to correct the remaining errors. Before revalidating the corrected LAR, examination staff will request that an institution provide monitoring and/or audit reports that document the actions taken to correct the data error(s). In these instances, examination staff will discuss with the institution’s management expectations for the scope and documentation of the monitoring and/or audit review. Examination staff will review the monitoring and/or audit findings and revalidate LAR data to test the effectiveness of the data correction.

Answer 105

True as provided in the administrative enforcement provisions of Regulation C.

Answer 106

Date the application was received or the date on the application form YYYMMDD. Enter NA for purchased covered loans.

Answer 107

Whether the loan or application is insured by the FHA, guaranteed by the Department of VA, Rural housing service, or farm service agency. 1-Conventional (not insured or guaranteed) 2-FHA 3-VA 4-USDA (RHS or FSA)

Answer 108

Whether the transaction is for home purchase, home improvement, refinancing, cash out refinancing, or another purpose. ``` 1-Home Purchase 2-Home Improvement 31-Refinancing 32-Cash out Refinancing 4-Other purpose 5-Not applicable ```

Answer 109

Whether the transaction involved a preapproval request for a home purchase loan under a preapproval program. 1-Preapproval requested 2-Preapproval not requested

Answer 110

Whether the dwelling is site build or a manufactured home 1-Site Built 2-manufactured home

Answer 111

Whether the property will be used as a principal residence, second residence, or investment property. 1-Principal Residence 2-Second Residence 3-Investment property

Answer 112

Amount of the loan or the amount applied for.

Answer 113

Type and date of action the FI took on the loan, application or preapproval request ``` 1-Loan originated 2-application approved but not accepted 3-application denied 4-application withdrawn by applicant 5-file closed for incompleteness 6-purchased loan 7-preapproval denied 8-preapproval approved but not accepted ``` Action taken should be YYYYMMDD

Answer 114

Address of the Property securing the Loan or proposed to secure the loan Street address City State Zip Code NA if the property address is not known or if the site of a manufactured home has not been identified

Answer 115

Location of the property securing the loan or proposed to secure the loan by state, county, and Census tract. Geocoded data of: County Census Tract State Enter NA if location is unknown or if site for manufactured home has not yet been identified.

Answer 116

Applicants or Borrower's ethnicity and if information was collected by visual observation of surname. Enter ethnicity of applicant/borrower or coapplicant/co borrower up to 5: 1-Hispanic or Latino 11-Mexican 12-Puerto Rican 13-Cuban 14-Other Hispanic or Latino (free form text field) 2- Non Hispanic or Latino 3-Information not provided by applicant 4- Not applicable (no requirement to report) 5- No co applicant (used in the co-applicant field) Ethnicity collection: Indicate whether the ethnicity of the applicant or borrower, or co applicant was collected using visual observation or surname. 1-Collected on basis of visual observation or surname 2-not collected on the basis of visual observation or surname 3- Not applicable (no requirement to report) 4-No co-applicant

Answer 117

Applicants or borrower's race and if information was collected by visual observation or surname. ``` Race: up to 5 1-American Indian or Alaskan native 2-Asian 21-Asian Indian 22-Chinese 23-Filipino 24-Japanese 25-Korean 26-Vietnamese 27-Other (free form field) 3-Black or African American 4-Native Hawaiian or other Pacific Islander 41-Native Hawaiian 42-Guamanian or Chamorro 43-Samoan 44-Other (free form) 5-White 6-Information not provided 7-Not Applicable 8-No co applicant ``` Basis of collection: 1-Collected on basis of visual observation or surname 2-not collected on basis of visual observation or surname 3- NA 4-No co applicant

Answer 118

Applicant's Sex and if information was collected by visual observation or surname. ``` Sex: 1-Male 2-Female 3-Information not provided. 4-NA 5-No coapplicant 6-Applicant selected both male and female. ``` Collection: 1-Collected on basis of visual observation 2-Not collected on the basis of visual observation 3-NA 4-No co applicant

Answer 119

Applicants age or borrower's age. or 8888- NA (purchased covered loans where bank chooses not to report, or when applicant is not a natural person) 9999-No co applicant (in the co applicant field)

Answer 120

If a credit decision is made, gross annual income relied on in making the credit decision, or in processing the application. Round all dollar amounts to nearest thousand. NA - not considered, not a natural person, secured by a multifamily dwelling, purchased loans where bank chooses not to report, privacy protection.

Answer 121

Type of entity that purchased the loan. 0-NA (non originated, preapproval denials/not accepted, originated or purchased loans bank did not sell during same calendar year.) 1-Fannie Mae 2-Ginnie Mae 3-Freddie Mac 4-Farmer Mac 5-Private securitizer 6-Commercial bank, savings bank, or savings association 71-Credit union, mortgage company, or finance company 72-Live insurance company 8-Affiliate institution 9-Other

Answer 122

Difference between the APR and average prime offer rate for a comparable transaction. Enter as a percentage w/ at least 3 decimal places. As of the date the interest rate is set. (can be positive or negative) NA- assumptions, reverse mortgages, purchased loans, not subject to reg Z. Exempt.

Answer 123

Whether the loan is a high cost mortgage under HOEPA. 1-High cost mortgage 2-Not a high cost mortgage 3-Not applicable (loans not subject to HOEPA, non originations)

Answer 124

Whether the property is a first or subordinate lien. 1-Secured by a first lien 2-secured by a subordinate lien

Answer 125

Credit scored relied on and the name and version of the credit scoring model. 1111-Exempt 7777-Credit score not a number (meets threshold scoring systems) 8888-NA 9999-No co applicant ``` Name and version of credit scoring model: 1111-Exempt 1-Equifax Beacon 5.0 (FICO score 5) 2-Experian Fair Issac Risk Model V2 (FICO v2) 3-Transunion FICO risk score classic 04 4-Transunion FICO risk score classic 98 5-Vantage Score 2.0 6-Vantage Score 3.0 7-More than one credit scoring model 8-Other credit scoring model (enter specifics into the field. 9-NA 10-No co applicant ```

Answer 126

Reasons the application was denied. Principal reason for denial. ``` 1111-Exempt 1-DTI 2-Employment history 3-Credit history 4-Collateral 5-Insufficient Cash (down payment, closing costs) 6-Unverifiable information 7-Credit application incomplete 8-Mortgage insurance denied 9-Other (use free form field) 10-NA (applications not denied) ``` If the bank uses the model form from ECOA for Notice of action taken use the following: Code 1—Income insufficient for amount of credit requested, and Excessive obligations in relation to income Code 2—Temporary or irregular employment, and Length of employment Code 3—Insufficient number of credit references provided; Unacceptable type of credit references provided; No credit file; Limited credit experience; Poor credit performance with us; Delinquent past or present credit obligations with others; Number of recent inquiries on credit bureau report; Garnishment, attachment, foreclosure, repossession, collection action, or judgment; and Bankruptcy Code 4—Value or type of collateral not sufficient Code 6—Unable to verify credit references; Unable to verify employment; Unable to verify income; and Unable to verify residence Code 7—Credit application incomplete Code 9—Length of residence; Temporary residence; and Other reasons specified on the adverse action notice.

Answer 127

Either total loan costs, or total points and fees charged. Dollar amounts NA or Exempt

Answer 128

Total borrower paid origination charges. Dollar amount. NA or exempt

Answer 129

Points paid to the creditor to reduce the interest rate. Dollar amount. NA or exempt

Answer 130

Amount of lender credits. Dollar amount. NA or exempt

Answer 131

Interest rate on the approved application or loan. Percentage with at least 3 decimal places. ex:4.125% NA (no originated) or exempt

Answer 132

Term in months of any prepayment penalty. NA or exempt

Answer 133

Ratio of the applicants or borrower's total monthly debt to total monthly income relied on. Enter as a percentage up to 15 decimal places. NA-Purchased loans, no credit decision, credit decision w/o relying on DTI, non natural persons, secured by multifamily dwelling.

Answer 134

Ratio of the total amount of debt that is secured by the property to the value of the property that was relied on. enter as a percentage up to 15 decimal places. NA- purchased loans, no credit decision, credit decision w/o relying on LTV. Exempt.

Answer 135

Number of months after which the legal obligation will mature or terminate. Term is in months. ex: 360 NA-loan or application w/o definite term Exempt

Answer 136

Number of months until the first date the interest rate may change. NA-fixed rate loan, purchased loan with fixed rate. Exempt

Answer 137

Whether the transaction involves a balloon payment, interest-only payments, negative amortization, or any other type of non-amortizing feature. BALLOON PAYMENT. Indicate whether the contractual terms include, or would have included, a balloon payment by entering:  Code 1111—Exempt  Code 1—Balloon payment  Code 2—No balloon payment INTEREST-ONLY PAYMENTS. Indicate whether the contractual terms include, or would have included, interest-only payments by entering:  Code 1111—Exempt  Code 1—Interest-only payments  Code 2—No interest-only payments NEGATIVE AMORTIZATION. Indicate whether the contractual terms include, or would have included, a term that would cause the covered loan to be a negative amortization loan by entering:  Code 1111—Exempt  Code 1—Negative amortization  Code 2—No negative amortization OTHER NON-AMORTIZING FEATURES. Indicate whether the contractual terms include, or would have included, any term, other than those described in § 1003.4(a)(27)(i), (ii), and (iii) that would allow for payments other than fully amortizing payments during the loan term by entering:  Code 1111—Exempt  Code 1—Other non-fully amortizing features  Code 2—No other non-fully amortizing features

Answer 138

Value of the property securing loan in dollar amount. NA- no credit decision, credit decision w/o property value. exempt

Answer 139

Whether the covered loan is secured by a manufactured home and land or a manufactured home and not land.  Code 1111—Exempt  Code 1—Manufactured home and land  Code 2—Manufactured home and not land  Code 3—Not applicable (not manufactured home, manufactured home community)

Answer 140

Information about the applicants or borrower's ownership or leasehold interest in the land where the manufactured home is located. ``` 1111-Exempt 1-Direct ownership 2-Indirect ownership 3-Paid leasehold 4-Unpaid leasehold 5-NA (not a manufactured home, manufactured home community, location not identified) ```

Answer 141

Number of individual dwelling units related to the property

Answer 142

Number of individual dwelling units related to the property that are income restricted under federal, state, or local affordable housing programs. 0-if not income restricted dwelling units NA- not a multifamily Exempt

Answer 143

Indicators of whether the application was submitted directly to the bank and if the obligation was initially payable to the bank. SUBMISSION OF APPLICATION. Indicate whether the applicant or borrower submitted the application directly to your institution by entering:  Code 1111—Exempt  Code 1—Submitted directly to your institution  Code 2—Not submitted directly to your institution  Code 3—Not applicable (purchased loans) INITIALLY PAYABLE TO YOUR INSTITUTION. Indicate whether the obligation arising from the covered loan was, or, in the case of an application, would have been, initially payable to your institution by entering:  Code 1111—Exempt  Code 1—Initially payable to your institution  Code 2—Not initially payable to your institution  Code 3—Not applicable (purchased loans, nonoriginated)

Answer 144

The NMLSR unique identifier for the mortgage loan originator. NA or exempt

Answer 145

Name of the automated underwriting system used by the bank to evaluate the application and the result generated by the system. AUTOMATED UNDERWRITING SYSTEM. Indicate the automated underwriting system(s) (AUS) used by your institution to evaluate the application by entering up to five (5) of the following:  Code 1111—Exempt  Code 1—Desktop Underwriter (DU)  Code 2—Loan Prospector (LP) or Loan Product Advisor  Code 3—Technology Open to Approved Lenders (TOTAL) Scorecard  Code 4—Guaranteed Underwriting System (GUS)  Code 5—Other (free form)  Code 6—Not applicable  Code 7—Internal Proprietary System ``` AUTOMATED UNDERWRITING SYSTEM RESULT. Indicate the result(s) generated by the automated underwriting system (AUS) previously indicated by entering:  Code 1111 —Exempt  Code 1—Approve/Eligible  Code 2—Approve/Ineligible  Code 3—Refer/Eligible  Code 4—Refer/Ineligible  Code 5—Refer with Caution  Code 6—Out of Scope  Code 7—Error  Code 8—Accept  Code 9—Caution  Code 10—Ineligible  Code 11—Incomplete  Code 12—Invalid  Code 13—Refer  Code 14—Eligible  Code 15—Unable to Determine  Code 16—Other (free form)  Code 17—Not applicable  Code 18—Accept/Eligible  Code 19—Accept/Ineligible  Code 20—Accept/Unable to Determine  Code 21—Refer with Caution/Eligible  Code 22—Refer with Caution/Ineligible  Code 23—Refer/Unable to Determine  Code 24—Refer with Caution/Unable to Determine ```

Answer 146

Indicator whether the transaction is for a reverse mortgage. 1111-Exempt 1-Reverse mortgage 2-Non reverse mortgage

Answer 147

1111-Exempt 1-OELOC 2-Not OELOC

Answer 148

1111-Exempt 1-Primarily for business or commercial purposes 2-not primarily for business or commercial purposes

Answer 149

The data related requirements in HMDA and Regulation C serve three primary purposes: (1) to help determine whether financial institutions are serving their communities’ housing needs; (2) to assist public officials in distributing public investment to attract private investment; and (3) to assist in identifying potential discriminatory lending patterns and enforcing antidiscrimination statutes.

Answer 150

No this loan is exempt from coverage. The bridge or swing loan is excluded as temporary financing.

Answer 151

The construction loan is excluded as temporary financing.

Answer 152

Yes. The construction loan is not temporary financing because it is not designed to be “replaced by” separate permanent financing. its is not exempt under the temporary financing provision.

Answer 153

Yes it does not meet the temporary financing exclusion. The loan is not temporary financing because it is not designed to be “replaced by” separate permanent financing.

Answer 154

Because Pine Bank made the credit decision prior to closing, Pine Bank reports the transaction as an originated Covered Loan, not as a purchased Covered Loan. Ficus Bank does not report the transaction.

Answer 155

Because Pine Bank makes the credit decision, Pine Bank reports the Application as denied. Ficus Mortgage Company does not report the Application. If, under the same facts, the Application is withdrawn before Pine Bank makes a credit decision, Pine Bank reports the Application as withdrawn, and Ficus Mortgage Company does not report the Application.

Answer 156

Ficus Bank reports the loan as an originated Covered Loan. Pine Bank reports the loan as a purchased Covered Loan.

Answer 157

Pine Bank reports the Application or, if the Application results in a Covered Loan, it reports the loan as an originated Covered Loan. If the Application results in a Covered Loan and Ficus Mortgage Company purchases it after closing, Ficus Mortgage Company reports the loan as a purchased Covered Loan.

Answer 158

Aspen Bank reports the loan as an originated Covered Loan. Pine Bank reports the Application as denied. Elm Bank reports the Application as approved but not accepted. Ficus Bank does not report the Application.

Answer 159

In 2018, a partial exemption applies to Ficus Bank’s Closed-End Mortgage Loan transactions, but a partial exemption does not apply to Ficus Bank’s Open-End Line of Credit transactions. Additionally, because Ficus Bank originated at least 500 Open-End Lines of Credit in both 2016 and 2017, Ficus Bank cannot exclude Open-End Lines of Credit from its reportable transactions in 2018 (i.e., they are not Excluded Transactions as discussed in Section 4.1.2).

Answer 160

Because Ficus Bank chose to report the balloon payment data field, Ficus Bank must also report whether the Covered Loan has interest-only payments, negative amortization, and other non-amortizing features. If a Financial Institution opts to report a data point with multiple fields, it must report all of the data fields that make up that data point.

Answer 161

Because a Financial Institution must report all of the aggregate race categories that an applicant selects and can only report a combined total of up to five aggregate race categories and race subcategories, Ficus Bank reports only the five aggregate race categories. It does not report the Chinese race subcategory.

Answer 162

The Financial Institution must report the White, Asian, and Native Hawaiian or Other Pacific Islander aggregate race categories. The Financial Institution also reports two of the three race subcategories. The Financial Institution chooses which two race subcategories to report (i.e., Korean and Vietnamese, Korean and Samoan, or Vietnamese and Samoan).

Answer 163

A Home Purchase Loan is a Closed-End Mortgage Loan or Open- End Line of Credit that is for the purpose, in whole or part, of purchasing a Dwelling. A Home Purchase Loan includes: (a) a Closed-End Mortgage Loan or Open-End Line of Credit secured by one Dwelling and used to purchase another Dwelling; (b) a combined construction-to-permanent loan that is secured by a Dwelling; (c) a separate permanent loan that replaces a construction-only loan or line of credit to the same borrower if the permanent loan is secured by a Dwelling; and (d) a Dwelling-secured subordinate mortgage loan that finances some or all of the home purchaser’s down payment.

Answer 164

A Home Improvement Loan is a Closed-End Mortgage Loan or Open-End Line of Credit that is for the purpose, in whole or part, of repairing, rehabilitating, remodeling, or improving a Dwelling or the real property on which the Dwelling is located. For example, a Home Improvement Loan includes: (a) a Covered Loan if any of the proceeds are used for repair, rehabilitation, remodeling, or improvement of the Dwelling or the real property on which the Dwelling securing the Covered Loan is located, even if the remainder is used for totally unrelated purposes, such as college tuition; (b) a Covered Loan used to install a swimming pool, construct a garage, or improve landscaping on the real property on which the Dwelling securing the Covered Loan is located; and (c) a Covered Loan used to improve a Multifamily Dwelling used for residential and commercial purposes if the proceeds are used either to improve the entire property (e.g., to replace a heating system that services the entire structure) or primarily to improve the residential portion of the Multifamily Dwelling.

Answer 165

A Refinancing is a Closed-End Mortgage Loan or Open-End Line of Credit in which a new Dwelling-secured debt obligation satisfies and replaces an existing Dwelling secured debt obligation by the same borrower. Generally, whether the new debt obligation satisfies and replaces an existing obligation is determined by reference to the parties’ contract and applicable law. In order for a Covered Loan to be a Refinancing, both the new and existing transactions must be secured by a Dwelling. Only one borrower need be the same on the new and existing transactions.

Answer 166

A Financial Institution reports a Covered Loan or an Application as a cash-out Refinancing if it is a Refinancing and the Financial Institution considered it to be a cash-out Refinancing when processing the Application or setting the terms under its or an investor’s guidelines. For example, if a Financial Institution considers a loan product to be a cash-out Refinancing under an investor’s guidelines because of the amount of cash received by the borrower at closing or account opening, it reports the transaction as a cashout Refinancing. If a Financial Institution does not distinguish between a cash-out Refinancing and a Refinancing under its own guidelines, sets the terms of all Refinancings without regard to the amount of cash received by the borrower at loan closing or account opening, and does not offer loan products under investor guidelines, it reports all Refinancings as Refinancings, not cash-out Refinancings.

Answer 167

If a Covered Loan is not, or an Application is not for, a Home Purchase Loan, a Home Improvement Loan, a Refinancing, or a cash-out Refinancing, a Financial Institution reports the purpose as “other.” For example, if a Covered Loan is for the purpose of paying educational expenses, the Financial Institution reports the purpose as “other.” A Financial Institution also uses “other” if the Covered Loan is or the Application is for a Refinancing but, under the terms of the existing credit agreement, the Financial Institution was unconditionally obligated to refinance the obligation subject to conditions within the borrower’s control.

Answer 168

Home purchase

Answer 169

Home purchase loan

Answer 170

Home purchase loan

Answer 171

Home purchase loan

Answer 172

Refinancing

Answer 173

Cash out refinancing

Answer 174

Refinancing

Answer 175

Cash out refinancing

Answer 176

Home improvement loan

Answer 177

When approving the Application, Ficus Bank relies on the appraisal. It reports the property value as $100,000.

Answer 178

DCP staff will use the general CMP matrices in the FIEA Manual when considering CMPs in connection with HMDA data. CMPs related to consumer compliance and fair lending violations, with the exception of CMPs related to pattern or practice flood violations, are determined using the general Matrix for CMPs against Institutions or Matrix for CMPs against Individuals (general CMP matrices). 2018 Data no CMPs allowed bc of new rules.

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