May 15, 2018
HMDA 2018
LEI & ULI
- Each financial institution obtains a unique LEI (Legal Entity Identifier) and each HMDA reportable loan application requires a ULI (Unique Loan Identifier)
- LEI is a 20 digit alphanumeric identifier and is annually renewed by Lender
- ULI is a maximum of 43 alphanumeric identifier consisting of LEI, loan application number and a 2 character check digit
- HELOC applications are now required to be reported – previously was optional
- Home Improvement applications not secured by real estate are no longer reportable
- Application Channel & Initially Payable to financial institution indicators
- Loan Purpose now includes refinances as being cash-out or refinance (replacing existing mortgage and include closing costs only)
- Subject Property Address
Required data points increased
- Loan Originator NMLS Identifier Number
- Construction Method (Site Built, Manufactured Home)
- If manufactured home, additional information required
- Secured Property Type – MH and Land or MH and not Land
- Land Property Interest – direct, indirect, paid leasehold, unpaid leasehold
- Property Value
- Total Units
- DTI
- CLTV
- Credit Score Information
- Automated Underwriting System (AUS) information
- Interest Rate & Introductory Rate if an ARM
- Contractual Features – Balloon, Negative Amortization, Interest-Only, Other
- Total Loan Costs, pursuant to Closing Disclosures (CD) on Line D
- Borrower Paid origination charges, pursuant to CD Line A
- Discount Points
- Lender Credits, pursuant to Line J on CD
- Loan Term – in months
- Occupancy Type (Principal, Second, Investment)
Changes to Borrower Government Monitoring Information (also referred to as Demographic Information)
- Ethnicity now has aggregate categories in addition to Hispanic or Latino
- Race now has additional categories and aggregate categories
- Only when application is taken face-to-face is Lender required to make selections if Borrower “Does Not
- Wish To Provide This Information”
- If borrower indicated do not wish to provide and application is face-to-face, Lender is required to inform borrower they have responsibility to make selections based on visual observation
- Note that if member/borrower comes into Lender office after initial application taken other than face-to-face, the rule that Lender to make selection applies, same as if application was taken face-to-face
- Borrower may select as many categories as desires/applies and Lender to report up to five of selected categories
- Lender should not deleted/change any borrower selection, just that up to five can be reported on LAR
Type of Purchaser – now has a N/A value if loan is not sold to a GSE or private investor or financial institution or affiliate
Disclosure Statements & Modified LAR will be available on the CFPB website
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Fannie May Updates
