Under the new HMDA regulation that will take effect in 2018, the term of the HMDA reportable loan must be entered on the HMDA LAR. This data point is relatively easy. A institution must report the number of months until the loan matures or terminates. If the loan does not have a definite term, like with reverse mortgages, the institution should report this data point as being “not applicable”. For open-end lines of credit that have a definite term, both the draw and repayment period counting from the account opening to the termination date should be included when reporting the loan term on the HMDA LAR.
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.