HMDA Purpose
If you are a HMDA reporting institution, knowing which applications are covered is the cornerstone of compliance. HMDA has a very low tolerance for reporting errors so if you report applications that you shouldn’t or don’t report applications you should, it’s very likely to result not only in violation but also having to resubmit your HMDA LAR. That’s not fun! A covered application must meet two tests:
- It’s dwelling secured; and,
- It’s for the Purchase, Refinance, Improvement or Other (aka consumer-purpose, home equity).
In other words, HMDA = Dwelling + Purpose.
A Purchase is defined as a closed-end mortgage loan or an open-end line of credit that is for the purpose, in whole or in part, of purchasing a dwelling.
David provides a few more things to consider when you’re trying to decide if you have a Purchase for HMDA.
Published
2025/02/05
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.