HMDA Data: Initially Payable to You
There are a lot of data points that you must report for each application on your HMDA LAR. Especially, if you are a Large Filer. Unfortunately, the more data points there are means that there are more chances to make errors. And, as you likely know, HMDA has a very low bar when it comes to the number of errors you can make.
One data field that sometimes causes confusion is the “Initially Payable to Your Institution”. The regulation says to report whether …the covered loan was, or in the case of an application, would have been initially payable to the financial institution…and to report not applicable…if the institution had not determined whether the covered loan would have been initially payable to the institution reporting the application when the application was withdrawn, denied, or closed for incompleteness.
Your options are:
Code 1 – Initially Payable to Your Institution
Code 2 – Not Initially Payable to Your Institution
Code 3 – Not Applicable
David explains more in the video.
Published
2025/02/10
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.