We were in the position with many of you that if there is no co-applicant we report "No Co-Applicant" on expressly withdrawn (EXWD) files. However like some above we also got validity errors V664-1 and V664-2. Our LAR software is through QuestSoft as well. They would not budge on this stance, so I reached out to HMDA Help via email on Friday. I got an actual email "written" response back, and as RIDICULOUS as it is, they (CFPB) confirms the position of QuestSoft that EVEN IF THERE IS NO CO-APPLICANT, when the file is EX-WD then you report the credit score and credit model fields as "NA".
I am going to go into our LAR today and change all to "NA". Also will be training our processors and updating our numerous internal guides (i.e. plain english translations for completing the HMDA fields at our bank).
Here is a copy/paste of that email from them. Even if it is still ridiculous, at least maybe you can feel "comfortable" that the CFPB directed this. I have found them to be quite responsive in their email answers back to me - a couple of their answers they would only call to discuss over the phone (no writing - boo).
-----Original Message-----
From: Elizabeth O'Hallaron
Sent: Monday, March 26, 2018 8:50 AM
To: Kristen Harper
Subject: [EXT] RE: HMDA 2018, Credit Score & Model when no co-applicant, but action taken is '4' EX-WD [ ref:_00 [ ref:_00Do0HJvn._500t09vAdZ:ref ]
Hello Kristen -
When the Action Taken is 4, 5, or 6, an institution should report the codes corresponding to Not Applicable, rather than No Co-Applicant, for the Co-Applicant Credit Score and Credit Scoring Model fields regardless of whether or not there is a co-applicant.
You can refer to 1003.4(a)(15)(ii) - comment 4 in the regulation for further information:
https://urldefense.proofpoint.com/v2/url...KSnrzOl8&e=Best,
HMDA Help
--------------- Original Message ---------------
From: HMDA Help [hmdahelp@cfpb.gov]
Sent: 3/23/2018 11:16 AM
Subject: RE: HMDA 2018, Credit Score & Model when no co-applicant, but action taken is '4' EX-WD [ ]
Hello,
Thank you for contacting the Consumer Financial Protection Bureau (CFPB) with your question.
We will escalate your issue to our technical team. Please allow up to three business days for a response.
Thank you,
CFPB HMDA Help
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--------------- Original Message ---------------
From: Kristen Harper
Sent: 3/23/2018 11:08 AM
To: hmdahelp@cfpb.gov
Subject: HMDA 2018, Credit Score & Model when no co-applicant, but action taken is '4' EX-WD
Good morning,
I am seeking guidance on the fields of Co-Applicant Credit Score, and Co-Applicant Credit Scoring Model when there is no co-applicant and the action taken is ‘4’ (expressly withdrawn by customer).
From my understanding of the FIG on page 76, it states that if there is no co-applicant, then enter code 9999 for co-applicant credit score, and enter code ‘10’ for co-applicant credit scoring model.
However, our LAR software provider believes that if the action taken is ‘4’, then we have to report the co-applicant’s score and model as “NAâ€â€¦ever if there is no co-applicant.
They are referencing the FIG on page 116 in regard to Validity Error
V664 which states if the action taken is ‘4’ then the co-applicant credit score must equal ‘8888’ and model must equal ‘9’.
I do not believe it was the intention of the CFPB to override the text from page 76 with the Edit ID guide on page 116 in cases where there is truly no co-applicant.
I agree that edit V664 should populate if there is a co-applicant and if the action taken is ‘4’.
But if there is no co-applicant at all, then those fields should correspondingly state such with ‘9999’ (no co-applicant, credit score) and ‘10’ (no co-applicant, credit scoring model).
Would you please clarify for us?