Be sure to JOIN US for our webinar, “HMDA Data for Small Filers”.
If you are a “small filer” for HMDA, there’s a lot of data you aren’t required to report when compared to a “large filer”. But, that doesn’t mean your data can be any less accurate. There are still plenty of data fields that cause small filers confusion. A couple of those are the applicant’s “Age” and the “Income” used in the credit decision.
David explains more in the video.
Transcript:
Then we get to age on page 39, and it says that it's whole years as of the application date. It is not as of closing. Don't update this.
Think about HMDA being an application regulation.
That's when you collect the demographic information, their age, et cetera, as of the application date. Let's go to income on page 40. The big deal here is whatever you relied upon. This is one of the top errors because there are usually so many different income figures in the file. What did the loan officer use to underwrite or did the underwriter use to support this? Make sure that you can prove that, document it, right? If it's a loan subject to the ability to pay, it should be the same. Now go to page 41 with me, and I want to point out here that employees, letter I. That'd be all insiders. Directors, officers, and employees. You do not need to report income.
You can report NA, it says there, but I want you to understand when it comes to loan to value, debt to income, and credit score, you still have to report those on those insiders. So they talk about it being for privacy reasons, but they still require you to report the loan to value, debt to income, and credit score if you're subject to those. We'll get to each one of these in a minute.
Letter J. I want to point out that it says "when the applicant or co-applicant is a non-natural person". Imagine my business, Banker's Compliance Consulting as an S Corp. It applies, and I say I will individually that loan as well. I volunteer that. Then, you would not have income because there's a business involved. Even though I'm on there because it says basically if either or of them, then we're out.
Published
2022/04/07
