HMDA is an application regulation. If you are a HMDA reporting institution, that is a statement that needs to be burned into the minds of your lenders for a number of reasons. First, HMDA wants information on all HMDA-reportable applications, not just the applications that result in an origination. In other words, HMDA wants you to report information on originations, denials, withdrawals, approved not accepted, etc. Some of the most important data fields you are required to report have to do with an applicant’s demographic information (i.e., their race, sex and ethnicity). You need to collect demographic information at the time of application.
David explains more in the video.