HOME MORTGAGE DISCLOSURE ACT AND REGULATION C Flashcards
What is the asset threshold amount used to determine if a credit union is exempt from HMDA reporting requirements?
$47 million.
A merger between two credit unions will have an effect on how the HMDA report should be filed and what information should be included. What is the effect when a covered credit union and an exempt credit union merge and the surviving credit union is the covered credit union?
For the year of the merger, data collection is required for the covered institution’s transactions and optional for transactions handled in the offices of the previously exempt credit union.
Credit unions must gather loan information on closed-end and open-end loans. However, the regulation expressly excludes nine types of loans from this requirement. List four of the nine types of loans excluded from HMDA reporting.
Loans on unimproved land; temporary financing; loans where the credit union is acting only in a fiduciary capacity; purchases of an interest in a pool of mortgages such as a mortgage participation certificate; purchases of servicing rights to loans; acquisition of only a partial interest in a home-purchase or homeimprovement loan even if the credit union participated in the underwriting and
origination of the loan (such as in certain consortium loans); pre-qualification requests that are not denied or do not result in an origination, loans acquired as
part of a merger; loans that are primarily for agricultural purposes.
The HMDA-LAR must report specific information. List eight pieces of required information.
An universal loan identifier, the date of the application was received; the loan type; the loan purpose; the owner-occupancy status; amount of the loan; action taken on the loan; the date the action was taken; the metropolitan area number; the state; the county; the census tract number; the race or ethnicity of the applicant and co-applicant; the sex of the applicant and co-applicant; the gross annual income used on the application; if the loan was sold, the purchaser and the lien status.
If a member refuses to supply information on race, ethnicity, or sex what steps should the loan interviewer take to supply that information with the loan application?
The loan interviewer should inform the applicant that the information is for government monitoring purposes only, federal law prohibits that discrimination based on this information, and that the information will be provided based on visual observation if not supplied by the applicant. When
a loan application is handled strictly by mail, Internet, or facsimile and the applicant does not provide the data, enter the code for “information not provided
by applicant in mail, Internet, or telephone application.”
What are the five criteria that if met, require a credit union to complete and submit an HMDA-LAR?
Assets meeting the threshold established each December by the Bureau; a home or branch office in a metropolitan area; origination of at least one federally related home-purchase loan in the preceding calendar year; is federally insured,
or has originated a federally insured loan, or has sold a loan to Fannie or Freddie; and has originated at least 25 closed-end loans in the two preceding calendar years, or has originated at least 200 open-end loans in the two preceding calendar years.
Credit unions are only required to report a loan once. What determines when the loan is reported?
Loans are reported in the year that final action is taken on the loan which is also known as the origination date. This date is reported on the HMDA-LAR in the “action taken” column.
What is the deadline date for submitting the HMDA report? What are the preferable methods for the reporting?
Credit unions must submit their HMDA report by March 1 of the year following the year the information applies to. Credit unions should submit data via the CFPB’s submission website.
