All HMDA reporters are required to have a Legal Entity Identifier (LEI) – this replaces the respondent ID on the transmittal sheet to identify the financial institution. The Universal Loan Identifier (ULI) includes the LEI, but is not required for depository institutions eligible for the S.2155 partial exemption. They may optionally report the ULI or a Non-Universal Loan Identifier (NULI).
Additional clarification is provided below:
If, pursuant to the 2018 HMDA Rule, your institution is not reporting ULI, enter a NULI assigned to the covered loan or application. Your financial institution shall assign and report an identifier that:
- Is composed of up to 22 characters;
- May be letters, numerals, or a combination of letters and numerals;
- Must be unique within the insured depository institution or insured credit union; and
- Must not include any information that could be used to directly identify the applicant or borrower.