Under the 2018 HMDA regulation, the value of the property that is (or will be used) to secure the loan must be reported. This data point depends upon which value the institution uses to determine the loan-to-value ratio. If the institution relies on the appraisal for this determination, then the appraised value is reported. The other option that an institution can rely on is the purchase price of the property. When entering the property value, the institution should enter the full amount with rounded to the nearest dollar. It is important to note that the method that is chosen should remain consistent throughout the HMDA LAR.
If the file was closed for incompleteness or withdrawn before a credit decision was made, then this data point should be reported as “not applicable”. This remains true even if the institution determined a value for the property before final action was taken. When an institution makes a credit decision without relying on the property value, then “not applicable” should also be entered 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.