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:
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