HMDA (Reg C) Flashcards
What is the MOST appropriate next step to take when the compliance professional is made aware of gaps in the bank’s HMDA (Regulation C) processes?
A. Report the gaps to Executive Management
B. Revise the bank’s HMDA training materials and policies
C. Post an updated resume on an online banking compliance job board
D. Determine the precise scope of the problem by doing preliminary investigations
D. Determine the precise scope of the problem by doing preliminary investigations
It is difficult to remediate gaps in compliance programs if the precise scope of the problem is unknown. This would be best accomplished by performing investigations into the extent of the problem. Reporting gaps to Executive Management without knowing the scope of the problems would be unwise at best. The same goes for revising materials and policies – what would those revisions state? They may be incomplete or inaccurate without knowing the full scope of the problem. And just because there are issues, there is no reason to post your resume!
A data integrity review for CRA and HMDA data submissions should include which of the following?
A. Analysis of loans made by geography
B. Analysis of applications by race, sex, and income
C. Verification of key data field accuracy
D. Verification that loan denials were denied in accordance with bank loan policy
C. Verification of key data field accuracy
Data integrity reviews involve exactly what the name suggests: the integrity (accuracy and reliability) of the data submitted under HMDA and CRA. Thus, verification of key data fields is essential in such an effort. Analyses of loans by geography and applications by race, sex, and income are both useful in fair lending-style analyses, but not for data integrity reviews. And while verifications that denials were performed according to bank policy are useful, it is also not an element of a data integrity review.
After a review of the bank’s Home Mortgage Disclosure Act (HMDA) procedures, which finding is MOST important to discuss with business leadership?
A. The bank is reporting all commercial-purpose applications secured by dwellings
B. “N/A” is reported under income for an application where the applicant is a corporation
C. The bank is not reporting applications for loans secured by farmland
D. The bank is not reporting applications for loans that are temporary in nature
A. The bank is reporting all commercial-purpose applications secured by dwellings
If a bank is reporting all commercial applications secured by dwellings, it would be reporting applications not mandated by HMDA. The regulation requires reporting of only commercial-purpose home purchase, home improvement, and refinancing applications. The other choices are accurate statements of HMDA’s requirements, so it would not be necessary to discuss them with management.
By policy, a bank does not collect income information on employee loan applications. When completing the HMDA LAR’s income field, the bank must record:
A. The zero dollar amount
B. The income information, regardless of its policy
C. The income information, but may use codes to protect the employee’s identity
D. NA for Not Applicable
D. NA for Not Applicable
According to HMDA guidelines covering how various fields should be populated, NA should be recorded for income on an employee loan application for obvious privacy reasons. The information should not be recorded at all.
Which of the following is MOST concerning when reviewing annual Home Mortgage Disclosure Act (Regulation C) submission reports and exception files?
A. Demographic information is reported in all Internet applications, even when the applicant refuses to provide it
B. Demographic information is reported in all applications received in-person, even when the applicant refuses to provide it
C. The bank reports commercial home purchase loan applications
D. When a counteroffer is accepted, the bank reports an origination for the amount of the loan, not the amount originally refused by the bank
A. Demographic information is reported in all Internet applications, even when the applicant refuses to provide it
Demographic information is not required in all Internet applications; the bank should not guess at the information when applicants refuse to provide it, as they cannot observe the applicant. Therefore, this would be concerning. The other choices are accurate statements of HMDA’s requirements, so they would not be concerning if observed during a review.
When preparing an action plan to validate the types of applications that should be included in HMDA reporting, which of the following is MOST important to include?
A. Consumer-purpose unsecured home improvement loans
B. Consumer-purpose dwelling-secured loans that modify existing loans to provide new money utilized to improve the borrower’s principal dwelling
C. Commercial-purpose loans to purchase warehouses, secured by multi-unit apartment buildings
D. Commercial-purpose lines of credit utilized to improve multi-unit apartment buildings, secured by the apartment buildings
D. Commercial-purpose lines of credit utilized to improve multi-unit apartment buildings, secured by the apartment buildings
HMDA coverage includes any consumer-purpose, dwelling-secured loan or line of credit. If the primary purpose of the loan or line is a commercial purpose, only home purchase, home improvement, and refinancing purposes are reportable. Thus, a commercial-purpose line of credit to improve the dwelling, secured by the dwelling, would be reportable. A commercial-purpose loan to purchase a warehouse, even though secured by a dwelling, would not be reportable since it is not a home purchase, home improvement, or refinancing. Unsecured loans or lines of any type are not reportable. There must be an “obligation” to be reportable; thus, a modification would not be reportable since there is no new obligation.
When evaluating a bank’s Home Mortgage Disclosure Act (Regulation C) platform, which of the following would be a concern?
A. Whether the data is complete and accurate
B. Whether the unique identifier is sequential
C. Whether the system includes unsecured loans
D. Whether the information is maintained for seven years
A. Whether the data is complete and accurate
Data integrity of a bank’s HMDA data is critically important, both for HMDA purposes as well as for fair lending analysis purposes. Whether the bank’s data is complete and accurate would surely be a concern. None of the other choices identifies a concerning factor under HMDA.
A bank originated 650 closed-end mortgages within the last calendar year. As the compliance professional, what is the BEST process to implement to comply with regulatory reporting requirements?
A. Perform one annual review of all HMDA-reportable records to validate data accuracy before submission of the Loan Application Register (LAR)
B. Perform periodic reviews of all HMDA-reportable records to validate data accuracy before submission of the Loan Application Register (LAR)
C. Submit the Loan Application Register (LAR) with the data as collected and recorded by the loan originators
D. It is not necessary to complete periodic reviews of all HMDA-reportable records, as the bank did not reach the required reportable threshold
B. Perform periodic reviews of all HMDA-reportable records to validate data accuracy before submission of the Loan Application Register (LAR)
HMDA requires that if the bank originated at least 100 closed-end dwelling secured loans, it must report the applications as part of their LAR. The bank did exceed this threshold. HMDA-reporting institutions are required to perform periodic reviews of their HMDA data to validate accuracy before submitting the data by March 1 of the following calendar year. These reviews are necessary and required.
On February 8, you assume responsibility as the compliance officer of a HMDA-reporting bank. Prior to March 1, you should:
A. Conduct a fair lending review.
B. Conduct a comparative file analysis of loans with rate spreads greater than 3%.
C. Ensure that the data to be submitted is accurate.
D. Compare the prior year’s HMDA results with the current year’s results.
C. Ensure that the data to be submitted is accurate.
Which of the following is MOST concerning when reviewing quarterly Home Mortgage Disclosure Act (Regulation C) reports?
A. Bulk purchases are included in the report
B. The quarterly error rate is consistent with prior quarters
C. Commercial loans are excluded from the report
D. Preapprovals are included if part of a formal program
C. Commercial loans are excluded from the report
If a bank acquires loans in bulk from another bank (for example, from the receiver for a failed institution) but no merger or acquisition of the institution/branch is involved, the institution reports the loans as purchased loans.
Commercial dwelling-secured applications are HMDA-reportable. Preapproved loans are also reportable if part of a formal program.
A consistent quarterly error rate isn’t ideal (unless that rate is extremely low or zero), but it is not as concerning as neglecting a HMDA-reportable category of loans (and applications).
What is a refinanced loan as defined by HMDA?
A. Any dwelling-secured consumer loan that replaces and satisfies another dwelling-secured loan.
B. Any dwelling-secured loan that replaces and satisfies another dwelling-secured home improvement loan.
C. Any dwelling-secured loan that replaces and satisfies another dwelling-secured loan. The purpose of the original loan is irrelevant.
D. Any dwelling-secured loan that replaces and satisfies another dwelling-secured home purchase loan.
C. Any dwelling-secured loan that replaces and satisfies another dwelling-secured loan. The purpose of the original loan is irrelevant.
Must HELOCs be reported for HMDA purposes?
HELOCs may be reported at the institution’s option if they are made for the purpose of home purchase or improvement – but report only the portion of the loan that represents the covered purpose.
True/False: Applications for preapprovals for home purchase loans that are denied or result in origination should not be reported.
False. They must be reported.
May HMDA data may be collected on separate registers for different branches or loan types?
Yes
HMDA data must be submitted to the supervisory agency in one complete package with what?
A. Supporting data
B. Board of director approval
C. Chief Lending Officer contact information
D. Officer certification of accuracy
D. Officer certification of accuracy
True/False: National banks and savings institutions have the option of reporting the reason for denial on the HMDA LAR.
False. They must report this. It’s optional for all other financial institutions.
Several types of loan-related data appear in the following list. Which type of data is NOT required to be reported under HMDA?
A. Data on multifamily housing
B. Data on unsecured home improvement loans
C. Data on refinancings of home purchase loans
D. Data on loans to purchase unimproved residential lots
D. Data on loans to purchase residential lots
Loans on unimproved land are not covered by the regulation. Unsecured home improvement loans may be reported if the institution classifies them as home improvement loans. If they are not classified as home improvement loans, they do not have to be reported.
The following statements make assertions about the collection and reporting of data on race, ethnicity, sex and income. Which statement is false?
A. It must be requested on all HMDA-reportable applications received in person from natural persons.
B. It must be requested only for the loans where the application is taken in person.
C. It must be reported unless the loan was purchased
D. It must be requested verbally on telephone applications.
B. It must be requested only for the loans where the application is taken in person.
The info on race, ethnicity, sex and income must be requested on all HMDA-related applications, even those received by telephone, mail or Internet. It does not have to be reported if the borrower fails to supply the information in an application that is not taken in a face-to-face interview. The institution does not have to report this information on purchased loans.
First National is subject to HMDA. On which of these loans does First National have to report the interest rate spread on its HMDA LAR?
A. A loan to remodel a 60-unit apartment complex.
B. A loan to renovate a rental property
C. An unsecured loan to purchase an investment property
D. A home improvement loan secured by a principal dwelling
D. A home improvement loan secured by a principal dwelling
The interest rate spread is only reported on loans subject to TILA.
By what date must financial institutions submit their loan application registers to their federal supervisory agency?
A. March 31 of the year following the calendar year for which the data were compiled.
B. March 1 of the year following the calendar year for which the data were compiled.
C. February 1 of the year following the calendar year for which the data were compiled.
D. April 1 of the year following the calendar year for which the data were compiled.
B. March 1 of the year following the calendar year for which the data were compiled.
If First National is subject to HMDA, which of the following loans would First National report on its LAR?
A. A refinancing of the balance of a home purchase loan made 5 years earlier, if both loans will be secured by dwellings.
B. A loan made to a couple, secured by their home, to pay for their children’s education.
C. A bridge loan made to a newly transferred executive of a local company
D. A loan made to construct a principal dwelling.
A. A refinancing of the balance of a home purchase loan made 5 years earlier, if both loans will be secured by dwellings.
Refinancings of home purchase loans when both loans are secured by dwellings are covered by the regulation. New loans made for purposes other than home improvement, home purchase and refinancings are not covered even if they are secured by real estate. Temporary loans, such as bridge loans and construction loans, are not covered.
When must a bank provide its mortgage loan disclosure statement?
A. Only when requested by its federal supervisory agency
B. At any time when requested by a member of the public
C. For 30 days following receipt of a request from its supervisory agency
D. On an ongoing basis, by posting it in the lobby of each branch.
B. At any time when requested by a member of the public
The mortgage loan disclosure statement must be made available to the public no later than 3 days after its receipt from the FFIEC, and the statement must be available for 5 years. The bank must post a notice of the public’s right to see the statement in the lobby of each office located within a MA.
My lazy dog sits, farts, yawns.
Mortgage / loan / disclosure /statement / five / years.
What information must be on the LAR for home loans on property located within the bank’s metropolitan area?
A. The county, census tract, and metropolitan area of the property
B. The address, census tract, and metropolitan area of the property
C. The county, address, and FMV of the property
D. The name, address and metropolitan area of the applicant.
A. The county, census tract, and metropolitan area of the property
How must most banks submit LAR to their federal supervisory agencies?
A. In machine-readable format
B. On the standard LAR form
C. In 3 copies with the required transmittal
D. In a separate package for each branch loan application
A. In machine-readable format
Banks with more than 25 LAR entries are required to submit electronically. Otherwise, two hard copies must be sent with the transmittal letter.
Which of the following is required to be reported on ABC Bank’s HMDA LAR?
A. An application from Mr. Welch for a preapproval of a home purchase loan application that is approved by ABC in writing but not accepted by Mr. Welch
B. An application from Ms. Ensley for a preapproval of a temporary construction loan that is denied by ABC
C. An application from Mr. and Mrs. Rawlings for a preapproval of a home purchase loan application that is denied by ABC
D. An application from Ms. Connor for a HELOAN to be used to consolidate credit cards.
C. An application from Mr. and Mrs. Rawlings for a preapproval of a home purchase loan application that is denied by ABC
Applications for preapprovals for home purchase loans must be reported if they are denied or if the loans are granted. Applications for preapprovals that are approved but not accepted are reportable at the institution’s discretion. Applications for nonreportable loans (the interim construction loan in (b) and the HELOAN for a non-HMDA purpose) are never reported.
John and Elise Fernandez apply to ABC Bank for a loan to purchase a manufactured home. ABC Bank is a community bank with approximately $100 million in assets and the home would be located outside of the bank’s metropolitan area. Mr. and Mrs. Fernandez complete an in-person application for a mobile home that is denied by the bank due to insufficient income. Which piece of information on the Fernandez application is ABC Bank NOT required to report on its HMDA LAR?
A. The ethnicity of the applicants
B. The race of the applicants
C. The purpose of the loan application
D. The metropolitan area where the home will be located.
D. The metropolitan area where the home will be located.
Because ABC does not have an office in the metropolitan area where the property is located, it does not have to report the property information on its LAR. It may do so at its option. All other info is required.
Which of the following loans or applications is EXCLUDED from HMDA reporting?
A. Residential loans purchased on the secondary market
B. Loans secured by real estate that are made for purposes other than home purchase, improvement or refinancing
C. Loans on residential property in a flood zone when proof of flood insurance is not provided
D. Applications for refinancing when there is no increase in principal.
B. Loans secured by real estate that are made for purposes other than home purchase, improvement or refinancing.
Only the types of loans mentioned in the “loans covered” and “compilation of loan data” sections are included in the coverage of HMDA - home purchase, home improvement or refinancing. Loans made for other purposes are not reportable.
For HMDA purposes, the term “dwelling” does NOT include which of the following?
A. Timeshares
B. Single family dwellings
C. Individual condos
D. Mobile homes not attached to real property
A. Timeshares
Of the following, which is the most likely to be a violation of Regulation C?
A. The MSA number, instead of the MSA name, is used for each loan and application
B. The “reasons for denial” column is blank
C. Race, national origin, and gender information are not included for purchase loans
D. The gender of the applicant is designated by the letters M or F
D. The gender of the applicant is designated by the letters M or F
Codes must be used to indicate sex of the applicant - not the letters “M” and “F”
An individual borrowed $1000 to remodel her mobile home. She lives in the mobile home that is not anchored to the ground. The loan will be secured by the mobile home, but the borrower does not own the lot on which it is parked. For HMDA purposes, this loan is considered to be which of the following types of loans?
A. Consumer RV
B. Home equity
C. Home improvement
D. Second mortgage
C. Home improvement
Under HMDA, what is the threshold for reporting the interest rate spread for first lien mortgage loans?
A. Equal to or greater than 3% points
B. Equal to or greater than 5% points
C. Equal to or greater than 7% points and when the loan is subject to HOEPA
D. Less than 8% points but greater than 5% points.
A. Equal to or greater than 3% points
In a review of a bank’s home mortgage loan application register, which of the following must be included?
A. Loans made or purchased in a fiduciary capacity
B. Servicing rights purchased
C. Interim construction loan applications
D. Loans made and sold within the reporting period
D. Loans made and sold within the reporting period
Applications for preapprovals that are approved by the institution but not accepted by the applicant ___ be reported.
may
A home improvement loan application was taken on December 2, 2015, but final action wasn’t taken until January 2, 2016. If the loan is HMDA reportable, will it be on the 2015 LAR?
No, because final action wasn’t taken in 2015. It will be reported in 2016.
Except for national banks and savings institutions, which of the following is optional when reporting for HMDA?
A. Owner-occupancy status of the property to which the loan relates
B. Amount of the loan or application
C. Type of action taken and the date
D. Reason for denial
D. Reason for denial.
This is optional, except for national banks and savings institutions
For HMDA, what 4 things must the bank report on the applicant or borrower?
- ethnicity
- race
- sex
- gross annual income relied on in processing the loan application
If the application is taken in a face-to-face interview, what must the lender do if the applicant chooses not to provide GMI?
The lender must inform the applicant that s/he must note the data based on visual observation.
If GMI was requested, but not provided on a telephone or mail application, what are the lender’s responsibilities?
If the applicant does not complete the information, the lender may state that the information was not provided.
What types of financing is excluded from HMDA reporting?
- Loans originated or purchased by the institution in a fiduciary capacity
- Loans on unimproved real estate
- Temporary financing (bridge loans or interim construction loans)
- Purchase of an interest in a pool of loans
- Purchase solely of servicing rights
- Loans acquired as a part of a M&A, or as a part of the acquisition of all of the assets and liabilities of a branch office.
For HMDA reporting, how quickly must data be updated after final action occurred?
Within 30 calendar days of the end of each calendar quarter.
What must the bank do if an inaccurate error was identified on the HMDA LAR to avoid a violation?
It must be found to be unintentional and the Bank must prove reasonable procedures are used throughout the year to ensure the accuracy of the compilations and reporting to their federal agency.
When must the HMDA loan data be sent to the regulatory agency that governs the financial institution?
March 1 of the year following the calendar year for which the loan data is compiled.
When must the bank make its mortgage loan disclosure statement available at its home office for inspection by the public?
Within 3 business days after it receives it from the FFIEC.
What are the requirements for banks making its mortgage loan disclosure statement available in branch offices?
It must be available within 10 business days after it receives it from the FFIEC in at least one branch office in each MA it has branch offices OR post the address in the lobby for requesting the statement in each branch office.
If a bank receives written request, how quickly must the bank mail or deliver a copy of the HMDA mortgage loan disclosure statement?
Within 15 calendar days
True/False: The disclosure statements available in the branch offices need only contain the loan information from the metropolitan area where that branch is located.
True
What does the modified LAR include?
Everything but the identification number, date the application was received, and the date the action was taken.
How long must HMDA mortgage loan disclosure statements be retained?
5 years from the time they are received from the FFIEC
How long must HMDA LARs and modified LARs be retained?
3 years
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HMDA / LAR / Three / Years
Are temporary loans HMDA reportable?
No, they are excluded from reporting.
A loan or line of credit is considered temporary financing and excluded from reporting if the loan/LOC is designed to be replaced by separate permanent financing extended by any financial institution to the same borrower at a later time.
Who is responsible for reporting the loan on the HMDA LAR?
A. The mortgage officer
B. The bank
C. The party who makes the final credit decision
D. The broker
C. The party who makes the final credit decision
The compliance professional of a small community bank is determining if HMDA data submission applies to the bank. When looking at the loan-volume threshold, the bank will need to determine
A. The number of loan applications received.
B. The number of closed-end home loans originated in the past year.
C. The number of closed-end and open-end loans originated in the prior calendar year.
D. The number of closed-end and open-end loans originated in the prior two calendar years.
D. The number of closed-end and open-end loans originated in the prior two calendar years.
A HMDA data analysis will NOT provide meaningful insights or conclusions about which of the following?
A. Need for additional employee CRA training
B. Need to redefine the bank’s assessment area
C. Focus of the bank’s next deposit-oriented marketing campaign
D. Specific neighborhoods to be targeted for additional outreach
C. Focus of the bank’s next deposit-oriented marketing campaign
The compliance officer is reviewing the bank’s most recent HMDA data prior to submission. Upon examining data for commercial applicants, the compliance officer notices that the race, sex, and income of the business’s owner is recorded. What is the BEST next step to take?
A. Eliminate the race, sex, and income on these applications since they are not reported for commercial applications
B. Eliminate the race and sex data from these applications since they are not reported for commercial applications, but leave the income information
C. Leave all the data as is, as they are required for all HMDA-reportable applications
D. Eliminate these applications from the HMDA submission file as they should not be reported
A. Eliminate the race, sex, and income on these applications since they are not reported for commercial applications
For commercial applications, HMDA does not require the reporting of race, sex, or income of the applicant, whether a business or sole proprietor. Provided the loan is secured by a dwelling and its purpose is home purchase, home improvement, or refinancing, commercial applications are HMDA-reportable.
The compliance officer is validating the business’s efforts in ensuring the bank’s information security program are appropriately met. When performing this task, all the following information must be subjected to monitoring under the program EXCEPT:
A. The bank’s publicly available HMDA data
B. The bank’s customer list
C. A list of all individuals (customers or not) who have used the bank’s ATMs over the past month
D. A list of all individuals who have applied for loans over the past year but were denied
A. The bank’s publicly available HMDA data
The bank’s publicly available HMDA data is not subject to monitoring under the bank’s information security program, because the information is publicly available and not subject to security protocols. Both customer lists and lists of individuals (customers or not) who have used the bank’s ATMs or have been denied for loans may be considered customers or “consumers” and subject to information security standards.
Are applications for a pre-qualification (or a pre-qual) reportable on the HMDA LAR?
No, because they have less information and underwriting. They also typically don’t have property locations, which are required for HMDA LAR reporting.
What types of loans are HMDA reportable?
A. Closed end if secured by a dwelling
B. Open and closed end if secured by a primary residence
C. Closed end if secured by real property
D. Open and closed end if secured by a dwelling
D. Open and closed end if secured by a dwelling
Which of the following are considered a dwelling for purposes of HMDA? Select all that apply.
A. A borrower’s primary residence
B. An apartment developer’s 50-unit apartment structure
C. A borrower’s 4-unit family residential dwelling that will have 1 unit owner-occupied and 3 units as rental property
D. A borrower’s vacation home
A, B, C, and D.
What two items are necessary for a refinance to be HMDA reportable?
A. Consumer purpose, new promissory note
B. New promissory note, both loans are secured by liens on a dwelling
C. Consumer purpose, both loans are secured by liens on a dwelling
D. Commercial purpose, both loans are secured by liens on a dwelling
B. New promissory note, both loans are secured by liens on a dwelling
If a borrower wants a loan to build a 50-unit apartment building, and is offering a lien on an existing 100-unit apartment building, is the application HMDA reportable?
Yes
Real Estate Residential Construction and Land Development loans might be HMDA Reportable if secured by a mortgage on a dwelling (or a dwelling to be constructed) and the loan is NOT a construction-only loan.
● If the loan was to purchase or construct a residential dwelling, it must be secured by a dwelling to be reportable. If the construction-perm loan (committed to both phases upfront) was secured by a residential dwelling, it would be reportable even though the purpose was to construct/purchase a spec-house or a rental home. Builder loans that are construction-only loans would not be reportable.
● If you committed only to finance the construction of the dwelling in the initial transaction, but later agreed to do a new loan (new note) to replace the temporary construction financing for the dwelling, don’t report the construction-only loan. The new loan for permanent financing would be reportable at the time you close on the permanent financing
What percentage of a home improvement loan must be used for home improvement to qualify as a HMDA reportable application?
Any
When must the HMDA LAR be submitted?
No later than March 1st
When is the modified LAR available to the public?
March 31st
Which of the following IS a dwelling under HMDA?
A. A manufactured home without a HUD certification sticker
B. A mobile home park
C. An RV park
D. A houseboat
B. A mobile home park
A dwelling includes a multifamily residential structure or community such as an apartment, condominium, cooperative building or complex, or a manufactured home community. 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 only by the land that constitutes the manufactured home community including sites for manufactured homes. However, a loan related to a multifamily residential structure or community that is not a manufactured home community is not secured by a dwelling for purposes of § 1003.2(f) if it is not secured by any individual dwelling units and is, for example, instead secured only by property that only includes common areas, or is secured only by an assignment of rents or dues.
Is the HMDA reporting of home equity lines of credit (HELOCs) optional, even if funds are used for home improvement purposes or to provide funds for a down payment on a home purchase loan?
Yes. Reg C specifically states that it is optional for banks to report home equity lines of credit made in whole or in part for the purpose of home improvement or home purchase.
If the bank chooses to report HELOCs for HMDA, the bank should report all HELOCs intended for home improvement or home purchase purposes, even if the borrower does not advance on the line of credit.
If the bank modifies, but does not refinance, a temporary construction loan into permanent financing, does this loan become a HMDA-reportable loan?
Yes. When permanent financing replaces a construction-only loan, the loan should be reported for HMDA. In addition, construction-permanent loans must also be reported for HMDA. In essence, the bank has replaced its temporary construction loan with permanent financing through this loan modification. Because it is no longer a temporary loan and has not been previously reported, it should be reported as a home purchase loan if it meets Reg C’s definition of home purchase.
What is the HMDA asset size exemption threshold?
A. At or below $56 million as of December 31, 2023
B. At or below $53 million as of December 31 for the prior two calendar years
C. At or below $53 million as of December 31 for one of the prior two calendar years
D. At or below $76 million as of December 31, 2023
A. At or below $56 million as of December 31, 2023
Banks, savings associations, and credit unions with assets at or below $56 million as of December 31, 2023, are exempt from collecting data for 2024.
What dwelling-secured loan purposes are HMDA-reportable? Select all that apply.
A. Consumer purpose home equity loan
B. Commercial home purchase
C. Commercial refinance
D. Commercial home improvement
A, B, C and D
All consumer and commercial home purchase, refinances, and home improvement loans are HMDA reportable if they’re secured by liens on a dwelling. Consumer purpose home equity loans are also HMDA reportable.
Are agriculture loans subject to HMDA?
A. Yes, if it is secured through a farmhouse on the property
B. Yes, commercial agriculture loans are subject to HMDA if it’s a temporary loan through the growing season
C. No, agriculture loans are exempt
C. No, agriculture loans are exempt
Agricultural purpose trumps (cancels out) the HMDA reportability.
If a borrower requests a $200K home purchase loan secured by a dwelling, which of the following situations would be HMDA reportable?
A. An accepted counteroffer of $150K, which should be reported as an origination
B. A declined counteroffer of $150K, which should be reported for the original amount $200K as a denial
C. A declined counteroffer of $150K, which should be reported for the counteroffer amount as a denial
D. A and B
D. A and B
Counteroffers:
– If applicant does not accept the counteroffer or fails to respond, report as a Denial on the original terms requested
– If applicant accepts the counteroffer, the report as an Origination of the amount originated
True/False: The below are the available actions in the HMDA LAR:
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 request denied
8 - Preapproval request approved but not accepted
True
Which of the following is NOT a HMDA responsibility for the public seeking HMDA information?
A. Direct public members to the CFPB website
B. Place a poster in the lobby directing the public on how to access HMDA information
C. Provide a copy of the LAR upon request
C. Provide a copy of the LAR upon request
The HMDA data is made publicly available on the CFPB’s website. The requirement for a bank to provide their HMDA information to anybody who asks has been rescinded. Instead, banks must direct anybody asking to access it via the CFPB website. Banks must also have a poster in the lobby of every branch.
Which of the following are accurate recordkeeping requirements for HMDA? Select all that apply.
A. Banks must maintain HMDA data for three years
B. Banks must maintain disclosure statements for five years
C. Banks must maintain loan application register information for three years
D. Banks must update information regarding reportable transactions quarterly
A, B, C, and D
How many closed-end dwelling loans must a bank originate to require those loans be HMDA reportable?
A. 100 closed-end dwelling secured loans for each of the prior two years
B. 75 closed-end dwelling secured loans for one of the prior two years
C. 125 closed-end dwelling secured loans for each of the prior two years
D. 90 closed-end dwelling secured loans for one of the prior two years
A. 100 closed-end dwelling secured loans for each of the prior two years
How many open-end dwelling loans must a bank originate to require those loans be HMDA reportable?
A. 300 open-end dwelling secured loans for each of the prior two years
B. 250 open-end dwelling secured loans for one of the prior two years
C. Combined 150 open and closed-end dwelling secured loans for each of the prior two years
D. 200 open-end dwelling secured loans for each of the prior two years
D. 200 open-end dwelling secured loans for each of the prior two years
Which of the following national banks must keep an Inquiry/Application log?
A. A bank that had 50 or more home loan applications in the previous year
B. A bank that has $50 million or more in assets
C. A bank that is located in an MSA
D. A bank that has been required by the OCC to keep such a log because of complaints that its lending practices may be discriminatory
D. A bank that has been required by the OCC to keep such a log because of complaints that its lending practices may be discriminatory
First National Bank, with assets of $60 million, is located in a large urban area (which as been designated as an MSA). Which of the following is true of the bank’s fair housing recordkeeping requirements?
A. It must keep an Inquiry/Application Log of all home loans and home improvement loans.
B. It does not have to keep any records unless it had at least 50 applications for home purchase loans during the previous calendar year.
C. It must keep monthly information on all home loan applications (including purchase, permanent financing, and refinancing) regarding the number of applications received, the number denied, the number withdrawn and the number of loans closed.
D. It must keep its HMDA LAR updated quarterly.
D. It must keep its HMDA LAR updated quarterly.
National banks that are subject to HMDA fulfill fair housing recordkeeping requirements by completing their HMDA LAR and updating it within 30 days of the end of the calendar quarter.
