CFPB HMDA FAQ ULI 2 - Does Regulation C require a financial institution to provide the universal loan identifier (ULI) on loan documents?

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Q:   Does Regulation C require a financial institution to provide the universal loan identifier (ULI) on loan documents?
 
A:  No. Regulation C, 12 CFR §§ 1003.4(a) and 1003.5(a), require a financial institution merely to collect, record, and report a ULI for applications for covered loans that it receives, covered loans that it originates, and covered loans that it purchases for each calendar year. Regulation C does not require the inclusion of the ULI on loan documents themselves.

For general information on the ULI, see section 5.2 of the HMDA Small Entity Compliance
Guide and 12 CFR § 1003.4(a)(1)(i).
 
 
This Q&A was based on information contained in the Consumer Financial Protection Bureau’s HMDA FAQs document, version 4, dated July 28, 2020, which is updated from time to time.  This HMDA-related issuance may be found here:  https://files.consumerfinance.gov/f/documents/cfpb_HMDA_frequently-asked-questions.pdf
 

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