HMDA requires that you report EITHER Total Loan Costs and Total Points and Fees or indicate that neither reporting requirement applies by entering “NA” for both.
- Total Loan Costs – required for loans that are subject to the Ability-to-Repay (ATR) rule AND the TILA-RESPA Integrated Disclosure (TRID) requirements.
- Total Points and Fees – required for loans subject to the Ability-to-Repay (ATR) rule, but NOT the TLLA-RESPA Integrated Disclosure (TRID) requirements.
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