All in HMDA

There has been some question regarding how to report whether or not demographic information was collected based on a visual observation for applications that were not taken face to face.  Specifically, the question relates to the following field for each part of demographic information: “Collected on the Basis of Visual Observation or Surname.”

As is the case with new regulations, we are often left scratching our heads as to why a rule is done the way it is.  For those of you that are HMDA reporters, I’m sure you can relate with the 2018 changes that are now upon us.  In particular, one HMDA head scratcher is the new HMDA hierarchy for reporting the loan purpose.   This article explains why the CFPB made the change.

On December 21, 2017, the CFPB (as well as the OCC and FDIC) released a statement announcing the Bureau's intentions for enforcement with respect to errors for data collected in 2018 and reported in 2019 under the Home Mortgage Disclosure Act (HMDA).  Per the release, "the Bureau does not intend to...