HMDA – Getting it Right 2020

The Federal Financial Institutions Examination Council (FFIEC) issued the 2020 “A Guide To HMDA Reporting: Getting it Right!”.  This guide is to be used for HMDA Submissions due March 1, 2021. Regulatory Solutions, using its proprietary HMDA Software, has scrubbed over 9,000 HMDA loans/applications for financial institutions comparing the data on their 2019 and 2018 HMDA LARs to source documentation. Do not wait until 2021 to begin your HMDA scrub, contact Regulatory Solutions today. Let us provide your HMDA scrubs on either a monthly or quarterly basis so next year you will be ready to submit your HMDA LAR.  The 2020 “A Guide To HMDA Reporting: Getting it Right!” can be accessed at

Guide to HMDA Reporting: Getting it Right!

The FFIEC has released the 2019 edition of the “Guide to HMDA Reporting: Getting it Right!” which is available at The new edition contains information regarding the amendments made to HMDA by the Economic Growth, Regulatory Relief, and Consumer Protection Act and updated HMDA interpretive and procedural rules issued by the Consumer Financial Protection Bureau. 2019 is the year to Get it Right! Regulatory Solutions has developed proprietary HMDA scrub software and has the expertise to scrub your HMDA data on a monthly or quarterly basis. Our HMDA scrubs compare your HMDA LAR to source documents. An exception report is issued to enable you to make corrections and a summary of exceptions is provided to assist you in addressing any systemic issues. Contact Regulatory Solutions today to begin your HMDA Scrubs.

HMDA Scrubs And The New Reg C Rules

We are just over half way through the new year under the new Regulation C rules which changed the Home Mortgage Disclosure Act (“HMDA”) reporting requirements. Have you scrubbed your HMDA data in accordance with the new rules? If not, let Regulatory Solutions help! We have developed proprietary HMDA Scrub software to assist in the data integrity review of your HMDA data. Our software produces exception-based reports so that you know exactly what corrections need to be made by loan number. The report also provides you with a total number of exceptions and percentages based on data points.

If you are interested in Regulatory Solutions scrubbing your current HMDA data, please contact us at 855.734.7655 or email us through our contact page.


Quality Control HMDA Requirements

Did you know that your HMDA data plays an important role when you are selling your loans to various agencies?

Most agencies require the lender to submit various HMDA data points as part of the purchasing process. With the new HMDA regulation that just took effect in January 2018, this means that the expanded GMI will play a key role in the purchasing process for most agencies.  Freddie Mac in particular specifically requires the lender report the GMI, Rate Spread, and HOEPA information for each loan that Freddie Mac purchases.

Fannie Mae, FHA, and Rural Housing require more than just the reporting of HMDA data points. Before these agencies will consider purchasing loans from your institution, you must show that you have procedures in place and are complying with the current HMDA regulation as part of your Quality Control Program. FHA has an additional requirement that the HMDA information that is being reported be accurate.

At Regulatory Solutions we are here to help. We provide in-depth Quality Control reviews, HMDA Scrubs and other regulatory services to help you with your compliance needs.

Debt-to-Income Ratio New HMDA Reporting Requirement

Another addition to what must be collected as part of your HMDA data in 2018 is the borrower’s debt-to-income ratio. This must be reported if the DTI ratio was relied upon when the financial institution made their credit decision. This does not mean that in order for this data point to be reportable it had to be a deciding factor when the financial institution made their credit decision. The DTI ratio merely had to have been considered during the credit decision process.

On your HMDA LAR, this data point can be reported as being “not applicable” in a number of circumstances. One instance is if the DTI ratio was not relied upon when the credit decision was made. “Not applicable” can also occur when you are reporting on a purchased loan and for applications that were closed for incompleteness or withdrawn before a credit decision could be made. Another occasion where “not applicable” is reported on your HMDA LAR is when the applicant and the co-applicant are not natural persons. It is important to note that when reporting the DTI ratio, what is securing the loan will also affect what you report on your HMDA LAR.  When the loan is secured by a multifamily dwelling, this data point should be reported as “not applicable”.


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.

Discount Points, Lender Credits, and Interest Rate New HMDA Regs

For the new HMDA regulation, a financial institution will now have to report more information in regards to the terms of the loan. This includes such information as the total discount points, lender credits and the interest rate.

The total discount points that are paid to the creditor to reduce the interest rate can be found on page 2 of the Closing Disclosure on Line A.01.  If there were no discount points paid, then this data point should be left blank. The other data point that can be found on the Closing Disclosure is the total of lender credits which is on page 2 Line J.  Like with the discount points, if there were no lender credits, this data point should be left blank. If a revised Closing Disclosure was issued, then the revised amounts should be reported on the HMDA LAR.

Both of these data points are to be reported as “not applicable” in the same circumstances. The first is if the application did not end in origination. The second circumstance is if the loan or application is not subject to Regulation Z. The last instance is if it is a purchased loan with an application that was received prior to the effective date of Regulation Z.

Another item that must be reported as part of your HMDA data is the interest rate. This data point must be reported for loans that originated and for those that are approved but not accepted. For applications that were denied, withdrawn or closed for incompleteness, this data point should be reported as being “not applicable”.


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.

Regulatory Solutions Acquires Assets of Culp QC, Inc.

Birmingham, Ala. – Regulatory Solutions LLC is pleased to announce that it has acquired the assets of Culp QC, Inc., a provider of quality control, post closing audit services to the mortgage industry. This transaction will significantly increase Regulatory Solutions’ business as well as its presence throughout the United States. Culp QC will continue to operate as a separate division of Regulatory Solutions under the Culp QC name with offices in Owensboro, Kentucky. Terms are undisclosed.

“We are excited to welcome Culp QC’s employees and clients to our growing company,” said Betsy Reynolds, president and founder of Regulatory Solutions. “Culp QC is a great fit as we both share a common approach in providing quality products and services to the mortgage industry.”

Bruce Culp has grown Culp QC over the last 22 years and is retiring after 45 years in the mortgage business. “I feel confident that Culp QC will be in great hands,” he said. “Regulatory Solutions has the same unwavering focus on customer service as we do and an unmatched attention to detail. Their innovative technologies in providing quality control services will give Culp QC the ability to grow its business and provide exciting new services to clients.”

According to Reynolds, in 2011 she set out to provide practical real world regulatory compliance assistance to financial institutions and mortgage companies. “We now serve clients all over the Southeast and expect our growth to continue nationwide,” she said. “It is an exciting time for us as we continue to serve our expanding client base with quality regulatory solutions.” Last year, the company acquired the assets of Outsource Mortgage Consultants, Inc., in Lexington, Kentucky.

Regulatory Solutions: Regulatory Solutions, a certified Women’s Business Enterprise, is located in Birmingham, Alabama, and provides regulatory and compliance consulting services to banks, mortgage companies, credit unions and investors on a nationwide basis. The company specializes in post closing, pre-funding and servicing quality control reviews for the mortgage industry.

Culp QC, Inc.: Culp QC, Inc. located in Owensboro, Kentucky was founded in 1995 by Bruce Culp, is a leading provider of quality control services nationwide. Bruce Culp, its founder will be retiring after 45 years in the mortgage business.

To read the release on, click here.

One HMDA Data Point That Won’t Change Is The Loan Type

The loan type is one of the data points that will not undergo any changes under the new HMDA regulation. This information can be found on the application and the reporting process is very straightforward. If the loan is not insured by anyone, then it would be considered a Conventional loan and Code 1 would be reported. An institution reports Code 2 if the application is insured by the Federal Housing Administration (FHA). Also, if the Veterans Administration (VA) is guaranteeing the loan, then Code 3 is reported on the LAR. Finally, an institution reports the Loan Type as being Code 4 if the USDA Rural Housing Service (RHS) or the Farm Service Agency (FSA) is guaranteeing the application.


Consistency Is Key To HMDA Reporting Of Application Date

Under the new HMDA regulations that will take full effect in 2018, the Application Date is one of the HMDA reporting data points that will not change. Your financial institution will either report the date that the application was received or the date that is listed on the initial loan application. While the rule gives the institution leeway to choose which to report, the method should remain generally consistent throughout the entire reporting process.

How an institution treats a loan application can also effect which date is reported. An example of this is when within the same calendar year, the applicant asks to reinstate a counteroffer that had been previously rejected or when the applicant asks the lender to reconsider an application that had been denied, withdrawn, or incomplete. The institution has two options. It can consider it a continuation of the previous loan, in which case the original application date should be reported. Alternatively, it can also be treated as a new transaction, making the date of the request for reconsideration the date that is reported.

Figuring out the application date can be relatively easy for consumer applications; however commercial loans can be more difficult. For these types of loans that are HMDA reportable, it can be hard to determine which date to report as applications are not necessarily required.  One method that could be used by an institution for HMDA reporting of commercial loans is to report the date that the loan request was received.

Remember, consistency is key when reporting the application date.