HMDA – NA, zero, or blank???
When it comes to what’s the right answer, NA, zero, or blank, it depends on the field we’re talking about. For instance, let’s talk about the total loan costs, points, and fees – there are five different fields there! The latest filing instruction guide (FIG) tells us that loan costs, points, and fees and origination charges are to be entered as zero if there are no loan costs, points, fees or origination charges, but when it comes to discount points and lender credits if the answer is zero you leave it blank. Confusing, huh?!?
The CFPB has changed the answer on several of these data fields so we’ve taken the latest FIG and created a quick reference. It’s 16 pages, but it goes through every data item, row by row, and includes a quick summary, if you’re exempt as a small filer, when to enter NA, zero, or leave the field blank. I think you’ll find this resource useful!
This is what we’re going to talk about at our one-hour webinar on January 10th. Are you ready to submit your 2018 data? We’re going to look at the new rules and all the new data, get into the weeds on some of the tricky things, and also discuss the CFPB’s new HMDA submission platform. Join me on January 10th! Let’s make sure that your data’s right, and you’re ready to upload it before you hit submit. See you then!
Published
2019/01/03
Dave Dickinson
Jamie Gustafson
Jamie wears many hats at Banker’s Compliance Consulting. These include managing the administrative team and heading up the e-commerce division. Jamie incorporates her experiences as a former Sergeant in the military and small business owner to bring an energetic and passionate approach to all opportunities! She has a Master’s Degree in Organizational Management and will graduate with her Ph.D. in Business – in May 2023. When Jamie is not directing at BCC, she dabbles in hobbies such as soap and cheese making.