HMDA Action Taken: Applicant Conditions vs. Property Conditions

Being a HMDA-Reporting financial institution brings many challenges from a compliance perspective. Certain data must be collected, when applicable, and then also reported, all which leaves very little room for error. While each data field has its own nuances and things that can trip you up, the Action Taken field is one that consistently causes problems. One of the main reasons, is that some of the available action taken codes don’t quite line up with other Regulations that may also come into play, like Regulation B. For example, there may be instances where you deny a loan application in accordance with Regulation B but that same application will be reported as “Application Approved but not Accepted” for HMDA. Thus, you need to be in tune with how HMDA defines these options, and, in many cases, that starts with an understanding of “underwriting and creditworthiness conditions” and “customary commitment and closing conditions”.

David explains more in the video.

HMDA Resources!



David Dickinson

David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.

He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.

David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.

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HMDA Action Taken: Applicant Conditions vs. Property Conditions