The new HMDA regulation that will take effect in 2018 will require a financial institution to report a myriad of new information. One of these new data points is the total origination charges that are considered borrower paid either at or before closing. This information can be found on page 2 of the Closing Disclosure in Line A. In the case where a corrected Closing Disclosure was delivered and the total charges that are borrower paid have changed, then the corrected amount should be reported on the HMDA LAR.
This is a relatively straight forward addition to the HMDA LAR and there are a few circumstances where this data point will be reported as being “not applicable”. This will occur if the application did not result in origination or if the transaction itself is not subject to Regulation Z. Another reason that this would be “not applicable” is if it is a purchased loan with an application that was received prior to the effective date of Regulation Z.
For more information on HMDA regulations, 2018 data point changes or our HMDA compliance services, please call Rhonda Wannemuehler or Betsy Reynolds at 855-734-7655.