Data Points Covered by Partial Exemptions
The Bureau of Consumer Financial Protection issued an interpretive and procedural rule on August 31, 2018, to implement and clarify section 104(a) of the Economic Growth, Regulatory Relief, and Consumer Protection Act, which amended certain provisions of the Home Mortgage Disclosure Act (HMDA). The rule allows certain insured depository institutions and insured credit unions (based on thresholds for the number of closed-end and/or open-end loans originated during a given year) to be partially exempt for certain data point reporting. Below is a chart detailing the data points covered by the partial exemptions and the correct code to use on the HMDA LAR to signify exemption.
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Data Points Covered by Partial Exemptions
| Data Points Covered by Partial Exemptions | Correct Code for Exemption |
|---|---|
| § 1003.4(a)(1)(i) – Universal Loan Identifier | Unique, within the insured depository institution, loan or application identifier that can be up to 22 characters |
| § 1003.4(a)(9)(i) – Property Address (street address, city, zip code) | Exempt |
| § 1003.4(a)(12) – Rate Spread | Exempt |
| § 1003.4(a)(15) – Credit Score | 1111 |
| § 1003.4(a)(15) – Name and Version of Credit Scoring Model | 1111 |
| § 1003.4(a)(16) – Reasons for Denial | 1111 (Leave the remaining Reason for denial data fields blank) |
| § 1003.4(a)(17) – Total Loan Costs or Total Points and Fees | Exempt |
| § 1003.4(a)(18) – Origination Charges | Exempt |
| § 1003.4(a)(19) – Discount Points | Exempt |
| § 1003.4(a)(20) – Lender Credits | Exempt |
| § 1003.4(a)(21) – Interest Rate | Exempt |
| § 1003.4(a)(22) – Prepayment Penalty Term | Exempt |
| § 1003.4(a)(23) – Debt-to-Income Ratio | Exempt |
| § 1003.4(a)(24) – Combined-Loan-to-Value Ratio | Exempt |
| § 1003.4(a)(25) – Loan Term | Exempt |
| § 1003.4(a)(26) – Introductory Rate Period | Exempt |
| § 1003.4(a)(27) – Non-Amortizing Features Balloon Payment Interest-Only Payment Negative Amortization Other Non-Amortizing Features | 1111 (enter code for each one) |
| § 1003.4(a)(28) – Property Value | Exempt |
| § 1003.4(a)(29) – Manufactured Home Secured Property Type | 1111 |
| § 1003.4(a)(30) – Manufactured Home Land Property Interest | 1111 |
| § 1003.4(a)(32) – Multifamily Affordable Units | Exempt |
| § 1003.4(a)(33) – Submission of Application | 1111 |
| § 1003.4(a)(33) – Initially Payable to Your Institution | 1111 |
| § 1003.4(a)(34) – Mortgage Loan Originator Identifier | Exempt |
| § 1003.4(a)(35) – Automated Underwriting System (AUS) | 1111 (Leave the remaining AUS blank) |
| § 1003.4(a)(35) – Automated Underwriting System Result | 1111 (Leave the remaining AUS results blank) |
| § 1003.4(a)(36) – Reverse Mortgage Flag | 1111 |
| § 1003.4(a)(37) – Open-End Line of Credit Flag | 1111 |
| § 1003.4(a)(38) – Business or Commercial Purpose Flag | 1111 |