HMDA Compliance - HMDA Data Guide Updated for 2019

Back in October, we alerted you to the fact that the CFPB had released a new Filing Instructions Guide (FIG) for HMDA data collected in 2019.  As a result, we’ve updated our HMDA Data Guide.  Version 3.0 is available now in our free lending tools.  Please note that these additions will not impact the data you collected in 2018.  Rather, they apply to HMDA data collected in 2019, that will be submitted in 2020.

So, what changed?

1. Codes 18 – 24 were added to the list of options when reporting the results from an Automated Underwriting System (AUS):

18. Accept/Eligible
19. Accept/Ineligible
20. Accept/Unable to Determine
21. Refer with Caution/Eligible
22. Refer with Caution/Ineligible
23. Refer/Unable to Determine
24. Refer with Caution/Unable to Determine

The FIG does tell us that added codes 18 and 19 correspond to results frequently returned by FHA Total Scorecard.  Any of the added codes may also commonly be reported by the Guaranteed Underwriting System (GUS).  The FIG also clarifies that while it specifies certain codes as being commonly seen with certain underwriting systems, you should ultimately report the result you receive.  For example, the FIG says that the GUS commonly gives results that correspond to codes 3, 4, 10, 15, 18 – 24.  However, that doesn’t mean that those are the only results that can be reported for that system.

2. The names of the Credit Scoring models were also revised for Codes #3 and #4 (e.g. FICO Risk Score Classic 04 is now TransUnion FICO Risk Score Classic 04).

While the changes aren’t necessarily major changes, it’s still important you are aware of them.  Let’s be honest, there are few regulations that cause more headaches and confusion than HMDA!  If you’re looking for HMDA training, visit our store to register for HMDA: Are You Ready to Submit Your 2018 Data? coming on January 10^th and HMDA Transaction Coverage on January 22^nd.

Published
2019/01/07
Diane Dean