For a withdrawn file, we report NA for credit score relied on. Does this also apply to the co-applicant credit score field and model field if there is no co-applicant. Seems it would match the DI and report no co-applicant, but we are getting validity errors when we enter no co-applicant. It just seems backward to me.

From Official Interpretation to 1003.4(a)(15)


4.Transactions for which no credit decision was made.

If a file was closed for incompleteness or the application was withdrawn before a credit decision was made, the financial institution complies with § 1003.4(a)(15) by reporting that the requirement is not applicable, even if the financial institution had obtained or created a credit score for the applicant or co-applicant.

Does this also apply to the co-applicant credit score field and model field if there is no co-applicant.

No. If there is no co-applicant then you report 9999 and code 10.

Dan - That's what we originally input, but we are getting a validity error from our HMDA software (Questsoft) stating that the co-applicant fields should be 8888 and 9 if withdrawn, even if there is no co-applicant.

There is a validity error (V664) in the FIG that says that if the action taken is 4,5,or 6 (withdrawn, closed for incompleteness, purchased loan) then the credit score of Co-Applicant or Co-borrower must equal 8888 and name and version must equal 9. So it appears that if no decision was made the field is NA for both the applicant and co-applicant. Flies is the face of logic, but I guess they don't want to know about credit score/version so they don't care if there was a co-applicant or not.

No wonder the software vendors are having so many issues.

MarieR I would read that to mean if there was an applicant and a co-applicant then you would report 8888 which I would agree with but why on earth would you report 8888 when there is no co-applicant.

As RRJ stated - wonder everyone is confused.

Dan - I agree with your common sense, but edit V664 is specific to co-borrowers only. Unfortunately the requirement as it stands in the FIG won't let you do what would make sense, you'll get an edit error.

Has anyone raised this issue to the CFPB so we can maybe get it cleaned up in the future?

Page 44 - Data Field 63 - 9999 is a valid entry when there is no co-applicant.

Page 75 - b. Use Code 9999 in the co-applicant field if there are no co-applicants or co-borrowers.

Page 20 of the GIR -  Code 9999—No co-applicant NOTE: Use Code 9999 in the co-applicant field if there are no co-applicants or co-borrowers.

So, do you go by the filing instructions or the explanation of the validity error code?

We've been going by this, and if the action taken is 4 or 5 are reporting 8888 for both applicant and co-applicant, even if there is no co-applicant. For other action types, if there is no co-applicant, we report 9999.


4.Transactions for which no credit decision was made.

If a file was closed for incompleteness or the application was withdrawn before a credit decision was made, the financial institution complies with § 1003.4(a)(15) by reporting that the requirement is not applicable, even if the financial institution had obtained or created a credit score for the applicant or co-applicant. For example, if a file is closed for incompleteness and is so reported in accordance with § 1003.4(a)(8), the financial institution complies with § 1003.4(a)(15) by reporting that the requirement is not applicable, even if the financial institution had obtained or created a credit score for the applicant or co-applicant. Similarly, if an application was withdrawn by the applicant before a credit decision was made and is so reported in accordance with § 1003.4(a)(8), the financial institution complies with § 1003.4(a)(15) by reporting that the requirement is not applicable, even if the financial institution had obtained or created a credit score for the applicant or co-applicant.

.Transactions for which no credit decision was made.

If a file was closed for incompleteness or the application was withdrawn before a credit decision was made, the financial institution complies with § 1003.4(a)(15) by reporting that the requirement is not applicable, even if the financial institution had obtained or created a credit score for the applicant or co-applicant. For example, if a file is closed for incompleteness and is so reported in accordance with § 1003.4(a)(8), the financial institution complies with § 1003.4(a)(15) by reporting that the requirement is not applicable, even if the financial institution had obtained or created a credit score for the applicant or co-applicant. Similarly, if an application was withdrawn by the applicant before a credit decision was made and is so reported in accordance with § 1003.4(a)(8), the financial institution complies with § 1003.4(a)(15) by reporting that the requirement is not applicable, even if the financial institution had obtained or created a credit score for the applicant or co-applicant.

I'm still not convinced this is not referencing when there is an applicant and co-applicant. If there is no co-applicant then a credit score would not be obtained. If you report 8888 you are implying there is a co-applicant and their credit score was not used. How does would that relate to the other fields where you report no co-applicant such as the DI?

I'm not convinced either.

I'm going with 8888 if purchased, no score used, withdrawn, or closed for incompleteness and 9999 if there is no co-applicant. Thank goodness for the weekend.

FWIW - our bank has taken the route of 8888 in both applicant and co-applicant fields if the application is withdrawn, even if there is no co-applicant (like HMDAgal). Similar to the argument of which field to report the score relied upon in if we relied upon one score, we don't feel the score fields relate to the applicant/co-applicant reported on the LAR. We're going to report this way consistently, so if we're wrong - at least we're consistently wrong.

I spoke with QuestSoft last week. After March 1st, they are full power ahead working on the 2018 issues and plans to have a fix/update for some issues. I am hoping this will be one of the fixes.

As of this time, my platform codes it 9999. I will stick with that until further notice.

What if the applicant was denied because of no credit? There are no credit references and no credit score. I loaded the application as denied and the credit score as 7777 (credit score is not a number), but I don't think that this is correct. Should the credit score be 8888 for not applicable even though the credit score was a (partial) reason for the denial? BTW, there was no co-applicant with this application, so I loaded credit score as 9999 and there was not a validity edit.

You didn't rely on a credit score.

Paragraph 4(a)(15)

5. Transactions for which no credit score was relied on. If a financial institution makes a credit decision without relying on a credit score for the applicant or borrower, the financial institution complies with §1003.4(a)(15) by reporting that the requirement is not applicable.

Thank you. I should load my credit score model as code 9 (NA) as well, even though a TransUnion Credit report was pulled, correct?

This doesn't make sense to us but we can't get around the validity edit unless we change it all to 8888. Encompass won't allow us to this so I am manually changing these on the export and importing them into Centrax.

It's Centrax that is giving me to validity code and I've heard that Quest Soft is also working this way. Does anyone know if Wiz is doing the same?

I have so many erroneous V edits right now in WIz that I'm really just ignoring them, bOaty. They mainly concern the fact that there is no co-borrower. They are working on it and until that happens, I'm just disregarding all of it.

Ugh, RRJ! I hate to wait and sort all of this out later, our volume has grown so much with adding on HELOCS I'm afraid to get buried. Then again I'm going to make myself nuts trying to sort it all out.

Me too. But the alternative is to jump through some arduous hoops that I really don't care to jump through at this point.

On some of the points that I'm seeking further clarification on from the almight bureau, I'm keeping a spread of those so I can go back and tweak as needed.

For the pot of withdrawals, if they stick with an asinine answer for 'no score' vs 'no co-borrower' on that one, they should be easy enough to sort and fix later.

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

Confidentiality Notice: If you received this email by mistake, you should notify the sender of the mistake and delete the e-mail and any attachments. An inadvertent disclosure is not intended to waive any privileges.
--------------- 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 “NA”…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?