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When are Purchased Loans Reportable under HMDA?

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In the ever-evolving landscape of mortgage regulations, lenders often grapple with the question: "Are purchased loans HMDA reportable?" The Home Mortgage Disclosure Act (HMDA) requires certain financial institutions to report data on their home purchase and refinance loans. Understanding which loans to report under the HMDA can help lenders ensure compliance and avoid potential penalties. Let's delve into this query, breaking down key aspects to provide clear answers.

The Home Mortgage Disclosure Act (HMDA), enforced by the Consumer Financial Protection Bureau (CFPB), was enacted to prevent redlining and ensure lending institutions offer equal access to credit. Thus, understanding which loans to report is crucial for lenders to demonstrate fair lending practices.

What Types of Loans Are HMDA Reportable?

According to the CFPB, any covered financial institution that originates at least 25 home purchase loans or 100 home purchase, home improvement, or refinance loans in each of the two preceding calendar years is required to report HMDA data for those loan types.

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However, not all purchased loans are reportable. The CFPB provides a comprehensive list of what they consider "covered loans" under HMDA. These include conventional home purchase loans and certain nonconventional loans like USDA-guaranteed, VA-guaranteed, and FHA-insured loans. bridge loans, swing loans, and home equity loans are typically not HMDA reportable.

Covered Financial Institutions

Understanding if your institution is subject to HMDA reporting is the first step. Generally, depository institutions such as banks and credit unions, and non-depository institutions including mortgage companies, are covered if they meet the loan volume threshold.

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However, small institutions with limited mortgage volume or certain nonprofit organizations may be exempt from HMDA reporting requirements. It's essential to verify your institution's status with the CFPB or a compliance consultant.

Reportable Loan Data Points

Once you've determined that a loan is HMDA reportable, you must collect and report the required data. This typically includes the loan's interest rate, loan amount, loan term, and property location, among other details. The CFPB provides an extensive list of data points that must be reported for each covered loan.

Accurate record-keeping and data collection throughout the loan process are key to ensuring all required information is available for reporting. Additionally, lenders should implement reliable systems for reporting this data to the CFPB.

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HMDA Reporting Timeline and Schedule

Meeting HMDA reporting deadlines is crucial to avoid penalties. Financial institutions must report HMDA data annually, following the loan application record (LAR) submission schedule provided by the CFPB.

The CFPB typically requires lenders to submit their data within a specific period each year, often in March. However, the exact submission schedule may vary, so it's essential to stay updated on the current requirements.

HMDA Exemptions and Partial Exemptions

Not all financial institutions are required to report HMDA data. Certain exemptions apply to small institutions that meet specific criteria, such as having a low volume of mortgage loans or being a nonprofit organization.

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Partial exemptions also exist for institutions with loan volume below the full reporting threshold but above the exemption threshold. These institutions must report limited HMDA data, so it's vital to understand exactly what's required if your institution falls into this category.

In conclusion, navigating the complexities of HMDA reporting requires thorough understanding and implementation of guidelines. By familiarizing themselves with reportable loan types, data points, and submission schedules, lenders can ensure compliance and facilitate fair lending practices. Regularly staying updated on CFPB changes and consulting with compliance experts will help firms maintain a robust HMDA reporting strategy.