HMDA Flashcards
Who is responsible for complying with HMDA
Banks
Credit Unions
Saving Associations
What are the covered criteria the bank, saving associations, and credit unions have to meet
On 12/31 assets were in excess of the threshold established by CFPB
Had a branch in a MSA
Originated, refinanced at least one home purchase loan secured by a 1st lien on a 1 to 4 fAmily
Loan is insured by government
Originated in each of the two preceding calendar years 25 covered closed end loans or 100 covered open end lines of credit
Excemptions from HMDA are for profit mortgage institutions that
Did not have an office in a MSA
Had assets of $10 million or less
Nom banks, savings, and loans, have to meet these criteria to be be required to report HMDA data
Had a branch in a MSA
Received applications or orginated or purchased five or more home purchase, home improvement loans, or refinancing related to property located in the same MSA
Orginated in each of the two preceding calendar years at least 25 covered closed in mortgage or 100 covered open end lines of credit
What loans are HMDA reportable
Home purchase loans to purchase a dwelling
Home improvement for improving the real property where the dwelling is located
Refinancing dwelling secured debt obligation to the same borrower
Pre approval of home purchase loans if institution issues a written commitment
Loan assumptions
Preapproval written commitments can only contain
Conditions to require identification of a suitable property
Condition that no financial material changed occurred
Limited conditions not related to financial condition or creditworthiness of the applicant
HMDA reportable exclusions
Home improvement but not dwelling secured
Agricultural purpose
Business or commercial purpose
Secured by unimproved land
Temporary Financing
Transactions less than $500
Closed end loan where bank originated less than 25 in two years
Open end loans where bank originated less than 100 in two years
Preapproval requests that are open end line of credit, to purchase multi family, for reverse mortgages
WhAt is considered an applicant in
Oral or written request for credit made in accordance to the procedures used by the institution
What is a dwelling
Structure in US DC or Puerto Rico
Financial institutions must collect data for covered loans that it
Purchases
Originated
Received
Data regarding request under a preapproval program shall be reported if the request is
Denied
Approved but not accepted
Data must include the following for each application
Universal Loan Identifier
Application Date
Type of loan
Purpose of loan
Preapproval?
Construction Method
Occupancy Type
Loan Amount
Action Taken
Property Address
Location of property
Non bank mortgage lenders with five or more loans in a MSA must report
Property location for for such metropolitan area
Age reporting is not applicable for what type of loans
Purchased or guarantors
What income is reported for the borrower
Gross annual income