Q: How are the HMDA provisions regarding the collection of required data points being adjusted?
A: Effective January 1, 2018 and applicable to data reported in or after 2019 –
The 2015 HMDA Rule adds the data points specified in the Dodd-Frank Act as well as data points that the Bureau determined will assist in carrying out HMDA’s purposes. For example, the 2015 HMDA Rule adds new data points for age, credit score, automated underwriting information, debt-to-income ratio, unique loan identifier, property value, application channel, points and fees, borrower-paid origination charges, discount points, lender credits, loan term, prepayment penalty, and identification of other loan features. 12 CFR 1003.4. The 2015 HMDA Rule also modifies some existing data points. For an illustration of the data points that the 2015 HMDA Rule adds or modifies, see the Summary of Reportable HMDA Data – Regulatory Reference Chart.
A financial institution collects, records, and reports the new and modified data points under the 2015 HMDA Rule for applications on which final action is taken on or after January 1, 2018. If a financial institution receives an application in 2017 but takes final action on it in 2018, it is required to collect, record, and report the new and modified data points under the 2015 HMDA Rule. There is a special transition rule that applies to the collection of an applicant’s ethnicity, race, and sex. This special transition rule is discussed in Section 5.1.1.
A financial institution collects, records, and reports the new and modified data points, to the extent that they apply to purchased loans, for purchases of covered loans that occur on or after January 1, 2018.