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#2153369 - 11/13/17 09:37 PM Reporting HOEPA Status
MusicCityCRCM Offline
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If it is in our loan policy that we will not make HOEPA loans, would that justify reporting all of our HMDA loans as NA in the HOEPA Status data field? Or would we report all originations as code 2 - not a high-cost mortgage, and all non-originations and commercial loans as NA?

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#2153380 - 11/13/17 10:37 PM Re: Reporting HOEPA Status MusicCityCRCM
bOaty Offline
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I don't think you could just choose one code to use for the whole LAR, you would use 2 and 3 depending on if it's a commercial loan, a second home, primary residence, etc.

If only it were that easy because really who does HOEPA loans anyway?
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#2153382 - 11/13/17 10:45 PM Re: Reporting HOEPA Status MusicCityCRCM
raitchjay Online
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Joined: Oct 2009
Posts: 9,088
OK
Paragraph 4(a)(13)

1. HOEPA status—not applicable. If the covered loan is not subject to the Home Ownership and Equity Protection Act of 1994, as implemented in Regulation Z, 12 CFR 1026.32, a financial institution complies with § 1003.4(a)(13) by reporting that the requirement is not applicable. If an application did not result in an origination, a financial institution complies with § 1003.4(a)(13) by reporting that the requirement is not applicable.

Loans that have to be tested for HOEPA (consumer purpose and secured by the consumer's primary residence) ARE subject to HOEPA, so as Boaty says, you can't put NA for those. It either is or is not a HOEPA loan, but not NA.
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#2153653 - 11/15/17 04:14 PM Re: Reporting HOEPA Status MusicCityCRCM
MusicCityCRCM Offline
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Joined: Apr 2015
Posts: 228
Thank you! I'm working on constructing bank procedure specific HMDA worksheets for our lenders and we're trying to determine which questions we can answer for them to cause less confusion. I guess this won't be one of them.

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#2164728 - 02/15/18 06:25 PM Re: Reporting HOEPA Status MusicCityCRCM
Mel in WA Offline
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Joined: Mar 2013
Posts: 1,265
If you have a transaction that is consumer purpose, but secured by a second home, it does not have to be tested for HOEPA. Would you enter N/A?

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#2165079 - 02/16/18 09:36 PM Re: Reporting HOEPA Status MusicCityCRCM
Red Raiders Offline
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I think that is right. The CFPB's Reporting Not Applicable chart says for HOEPA Status you report "NA" for "Covered loans not subject to the Home Ownership and Equity Protection Act (HOEPA) of 1994, as implemented in Regulation Z..."
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