Updated 2018 HMDA Changes - Economic Growth, Regulatory Relief, and Consumer Protection Act

The CFPB just released updated 2018 HMDA submission requirements on Friday, August 31. These changes are for the 2018 data currently being collected, and must be used on this data that will be submitted in March 2019. There are both new and modified edits, as well as requirements for partially exempt institutions. We are still digesting the information as the documentation is quite verbose, as usual. We will be adding the submission changes to our Comply 18 release which is still expected to be available by the end of October, but wanted you to know that we are aware of the changes and are actively working on them.

Here is a link to the official site:
https://www.consumerfinance.gov/about-us/newsroom/bureau-consumer-financial-protection-issues-rule-implement-and-clarify-new-hmda-amendments/

The following fields are now exempt for reporters that meet the criteria. Institutions that are below the thresholds will report the exempt codes for any of the following fields that they choose not to report. The Comply system will give institutions full flexibility to report how they choose, correctly. Those above the threshold will be reporting all fields as previously defined, with a few edit updates.

• 13 Street Address - Exempt
• 14 City - Exempt
• 16 Zip Code - Exempt
• 59 Rate Spread - Exempt
• 62 Credit Score of Applicant or Borrower - 1111
• 63 Credit Score of Co-Applicant or Co-Borrower - 1111
• 64 Applicant or Borrower, Name and Version of Credit Scoring Model - 1111
• 65 Co-Applicant or Co-Borrower, Name and Version of Credit Scoring Model - 1111
• 68 Reason for Denial 1 - 1111
• 73 Total Loan Costs - Exempt
• 74 Total Points and Fees - Exempt
• 75 Origination Charges - Exempt
• 76 Discount Points - Exempt
• 77 Lender Credits - Exempt
• 78 Interest Rate - Exempt
• 79 Prepayment Penalty Term - Exempt
• 80 Debt-to-Income Ratio - Exempt
• 81 Combined Loan-to-Value Ratio - Exempt
• 82 Loan Term - Exempt
• 83 Introductory Rate Period - Exempt
• 84 Balloon Payment - 1111
• 85 Interest-Only Payments - 1111
• 86 Negative Amortization - 1111
• 87 Other Non-amortizing Features - 1111
• 88 Property Value - Exempt
• 89 Manufactured Home Secured Property Type - 1111
• 90 Manufactured Home Land Property Interest - 1111
• 92 Multifamily Affordable Units - Exempt
• 93 Submission of Application - 1111
• 94 Initially Payable to Your Institution - 1111
• 95 Mortgage Loan Originator NMLSR Identifier - Exempt
• 96 Automated Underwriting System 1 - 1111
• 102 Automated Underwriting System Result 1 - 1111
• 108 Reverse Mortgage - 1111
• 109 Open-End Line of Credit - 1111
• 110 Business or Commercial Purpose - 1111