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CFPB HMDA FAQs
CFPB HMDA FAQs
Legal Entity Identifier
If my institution doesn’t have a registered LEI, will our HMDA submission be rejected or fail?
For an existing LEI, how important is it for the office address to be updated to the recent address due to a move?
My institution recently changed names and our LEI does not show the new name on the GLEIF website. How do we correct the name?
If a merger occurs after January 1, 2021, do we need to submit using the new entity LEI for 2020?
Do we need to create a new account on the CFPB platform if we went through a merger, have a new bank name even if we have the same Tax ID?
Data Points / Fields
Are we required to complete the field for Business / Commercial Purpose if we don’t have any HMDA reportable transactions that are business purpose?
How do we report credit score, name and version of scoring model on withdrawn and incomplete applications when there is no co-borrower?
Are we supposed to report credit score and AUS data points for withdrawn and incomplete applications?
Are we required to report ALL credit information on denied applications?
If a borrower does not provide age or a date of birth, can we report Not Applicable for Age?
How are correspondent loans reported – purchased or originated?
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Why am I receiving a Q654 edit?
What is a macro quality edit?
What is a quality edit?
What is a validity edit?
What is a syntactical edit?
Q617 has been frustrating. Is manual verification required per individual loan file?
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Does the partial exemption mean credit unions are exempt from filing?
If you qualify for exempt reporting, are you still required to report the state of the property?
If we originated less than 500 loans in the past two years for closed-end, are we exempt from reporting HMDA?
Does an exempt credit union need to use an LEI?
Where can I view a chart of data points for exempt institutions?
Clarifying the partial exemption, would we be exempt if we "originate" fewer than 500 closed-end in BOTH 2017 & 2018? That would also apply to open-end, if less than 500 were "originated".
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How do I determine whether a business or commercial purpose loan is HMDA reportable?
If we originated open-end lines of credit under the required reporting threshold, can we optionally report?
What are census tract numbers that start with 9900?
What are the thresholds for reporting HMDA data?
When are quarterly HMDA submissions due?
Is the CFPB still requiring quarterly HMDA reporting due to the current COVID-19 pandemic?
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