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#2119060 - 02/22/17 03:41 AM HMDA+ vs New HMFA
run4fun Offline
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A coworker has mentioned HMDA+ and stated it is different from the new HMDA. I thought HMDA+ was just they way people were referring to the new HMDA rules. Aren't they? If not, where can I find information on how these things would vary. We are just reviewing the final HMDA regulation.

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#2119064 - 02/22/17 12:01 PM Re: HMDA+ vs New HMFA run4fun
rlcarey Online
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Galveston, TX
"A coworker has mentioned HMDA+ and stated it is different from the new HMDA."

I would be asking the co-worker what they are referring too.
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#2119176 - 02/22/17 09:49 PM Re: HMDA+ vs New HMFA run4fun
Darth HMDA, CRCM, CAMS Offline
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Ditto. I have not heard of "HMDA+"
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#2119251 - 02/23/17 04:14 PM Re: HMDA+ vs New HMFA run4fun
David Dickinson Offline
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Central City, NE
I haven't heard that term for several years, but IF I recall correctly, it was an OCC only program. It was an "option" for OCC banks that weren't subject to HMDA but went way beyond the Home Loan Data Sheet requirements of the Fair Housing Act.
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#2119254 - 02/23/17 04:20 PM Re: HMDA+ vs New HMFA run4fun
Carter'sMom Offline
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Joined: Aug 2015
Posts: 37
Our Federal Reserve examiners requested HMDA+ data for our exam in October of 2017. There were 40 additional fields they wanted to see. We were able to give them SOME of the fields but they are expecting us to provide ALL 40 for our next exam. I too am frustrated that HMDA+ fields are different from new HMDA.
Last edited by Carter'sMom; 02/23/17 04:22 PM.
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#2119255 - 02/23/17 04:21 PM Re: HMDA+ vs New HMFA run4fun
Skittles Offline
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Our Federal Reserve examienrs also requested the HMDA+ data for our exam in March 2017.
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#2119257 - 02/23/17 04:22 PM Re: HMDA+ vs New HMFA run4fun
Carter'sMom Offline
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Sorry, meant to say our exam in October 2016. :-)

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#2119306 - 02/23/17 07:10 PM Re: HMDA+ vs New HMFA run4fun
RR Joker Offline
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How can they just 'expect' for you to gather more data that what is required? This makes zero sense to me.
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#2119312 - 02/23/17 07:27 PM Re: HMDA+ vs New HMFA run4fun
RR Becca Offline
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out of the frying pan...
And if it isn't required, how can they hold it against you if you are unable to provide it when asked?
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#2119325 - 02/23/17 07:56 PM Re: HMDA+ vs New HMFA run4fun
Carter'sMom Offline
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Joined: Aug 2015
Posts: 37
I think some of the "expectation" in my case came from a previous compliance officer providing the data. Either way - here it is straight from my exam request letter...

Field Request (please append to the right of existing HMDA LAR fields)


1. Product Type (Flex 97, Conforming 30 Year Fixed, etc.)
2. Investor name
3. Lock Date
4. Lock Period
5. Total Loan Amount
6. Base Loan Amount
7. Loan Term in Months
8. Note Rate
9. APR
10. Lender Fees
11. Discount Fees
12. Lender Credits
13. Broker Fees Paid by Borrower (if applicable)
14. Investor Price Net of Loan Level Pricing Adjustments (i.e. 101.5)
15. Credit Score Used for Underwriting and Loan Pricing
16. LTV
17. CLTV
18. DTI Used in the Underwriting Decision
19. Institution Defined Property Type – SFR, multi-unit condo etc.
20. Documentation Type (full, streamline, none, etc.)
21. Final Automated Underwriting Decision
22. Cash Out Refinance (Y/N)
23. Escrow Waiver (Y/N)
24. Mortgage Insurance Premium (Y/N)
25. Prepayment period Penalty (Y/N)
26. Interest Only (Y/N)
27. ARM Loan (Y/N)
28. Rural Property (Y/N)
29. Balloon Loan (Y/N)
30. Portfolio or Secondary Market Loan
31. Channel Where Loan Originated
32. Branch Where Loan Originated
33. Loan Officer or Broker Code
34. Presence of Underwriting Exception (Y/N)
35. Type of Underwriting Exception
36. Presence of Price Exception (Y/N)
37. Type of Price Exception
38. Amount of Price Exception in Note Rate (if applicable)
39. Amount of Fee Exception (if applicable)
40. Broker or Loan Officer Compensation (Dollars)

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#2119330 - 02/23/17 08:12 PM Re: HMDA+ vs New HMFA run4fun
run4fun Offline
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Joined: Mar 2002
Posts: 98
Thanks all! We've previously been examined by the FDIC for HMDA compliance, but have recently crossed over the $10B threshold. Let the good times roll. 😕

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#2119335 - 02/23/17 08:21 PM Re: HMDA+ vs New HMFA run4fun
rlcarey Online
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Galveston, TX
Sounds like this is not truly HMDA related, but they are gearing up for a full scope fair lending examination.
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#2120350 - 03/03/17 04:48 AM Re: HMDA+ vs New HMFA run4fun
Reads Regs Offline
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Joined: Nov 2004
Posts: 2,285
I searched the OCC web site for the phrase "HMDA plus" and found the following.

Former OCC Comptroller John Dugan used the phrase HMDA plus in this 2008 speech. https://www.occ.gov/news-issuances/speeches/2008/pub-speech-2008-103.pdf

The phrase was mentioned in this 2010 OCC white paper. https://www.occ.gov/publications/publications-by-type/occ-working-papers/2012-2009/wp2010-1.pdf

The phrase also appeared in this 2015 OCC CRA Decision involving First Tennessee Bank. https://www.occ.gov/topics/licensing/interpretations-and-actions/2015/crad169.pdf
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