CFPB HMDA FAQ Multiple Data Pts 1 – Are financial institutions required to report the credit score, DTI and CLTV relied on in making a credit decision when such data is not the dispositive factor?

Compliance > Regulation C - HMDA > CFPB
Q:   Are financial institutions required to report the credit score, DTI and CLTV relied on in making a credit decision when such data is not the dispositive factor?
 
A:   Yes. Credit underwriting data such as credit score, debt-to-income ratio (DTI), and combined loan-to-value ratio (CLTV) must be reported if they were a factor relied on in making a credit decision—even if the data was not the dispositive factor. For purposes of Regulation C, it does not matter whether the application is approved or denied; if certain data was relied on in making a credit decision, such data must be reported.
 
For example, if the credit score was relied on in making a credit decision, the credit score must be reported. If the financial institution denied the application because the application did not satisfy one or more underwriting requirements other than the credit score, the financial institution is still required to report the credit score relied on. Comment 4(a)(15)-1. The same analysis applies to the reporting of CLTV and DTI. Comment 4(a)(24)-2 and 4(a)(23)-2.
 
For general information on the collection and reporting of HMDA data, see section 5 of the HMDA Small Entity Compliance Guide
 
 
This Q&A was based on information contained in the Consumer Financial Protection Bureau’s HMDA FAQs Compliance Aid, which may be updated from time to time.  This HMDA-related issuance may be found here: 
 
 

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