Can you explain when you report Total Loan Costs vs. Total Points and Fees? Are both ever reported for a loan?

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.