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.
Published
2024/05/06
