HMDA has a lot of intricacies, which make compliance a challenge. The first step is determining whether you have a HMDA-covered transaction, and this isn’t always as easy as it may seem. Both the collateral (a dwelling) and the loan purpose (purchase, refinance, home improvement and other consumer purpose), will determine HMDA coverage. Thus, knowing when something is a dwelling or not, is very important. HMDA has a very low threshold for errors. So, if you report applications that aren’t HMDA or you don’t report applications that are HMDA, your institution could be in hot water with examiners.
David discusses multifamily dwellings in the video.
Published
2025/02/28