HMDA Small Filers: Exempt Data
If you are a “small filer” for HMDA, there is a lot of data you are not required to report. The credit score, origination charges, interest rate, debt-to-income ratio, loan term, property value, etc. are just a few of many. But you do still have to be careful as there are some fields, like the credit score, where if you voluntarily report it, you must provide ALL of the related data included within that section. For example, if you voluntarily report the credit score of one applicant, you must also report the scoring model used. You also have to ensure you report those exempt fields correctly. For instance, if it’s a text field you must report the “exempt” or if it's a data field you must report 1111.
David explains more in the video.
Published
2025/02/17
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.