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#2164801 - 02/15/18 08:57 PM Discount Points & Lender Credit
laf0915 Offline
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We use Quest Soft-Compliance Relief for our Hmda reporting. For the above two fields, a chart that I am referencing from HMDA Academy says if no discount points, leave blank (do not enter 0 or NA) Same thing for Lender Credits. When I leave these fields blank in Compliance Relief, I get errors that say must be 0.00 or greater, or NA.

I am wondering if I am not understanding something correctly? Any compliance relief users out there that could lend some insight? Thank you.

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#2164803 - 02/15/18 09:01 PM Re: Discount Points & Lender Credit laf0915
NSF, CRCM Offline
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VA
I actually sent an email to Quest Soft concerning this last week and they responded this would be fixed in a future patch.
Last edited by NSF, CRCM; 02/15/18 09:02 PM. Reason: Grammar
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#2164810 - 02/15/18 09:20 PM Re: Discount Points & Lender Credit NSF, CRCM
laf0915 Offline
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Thank you NSF, CRCM. Helpful information.

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#2164812 - 02/15/18 09:25 PM Re: Discount Points & Lender Credit laf0915
David Dickinson Offline
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Central City, NE
Quote:
For the above two fields, a chart that I am referencing from HMDA Academy says if no discount points, leave blank (do not enter 0 or NA) Same thing for Lender Credits.

The FIG shows that we are to leave the fields blank for Discount Points and Lender Credits.
For Total Loan Costs; Total Points and Fees; and Origination Charges, if they are none, we are to enter "0".

Makes sense, right? frown
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#2164813 - 02/15/18 09:29 PM Re: Discount Points & Lender Credit David Dickinson
NSF, CRCM Offline
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Originally Posted By David Dickinson
Quote:
For the above two fields, a chart that I am referencing from HMDA Academy says if no discount points, leave blank (do not enter 0 or NA) Same thing for Lender Credits.

The FIG shows that we are to leave the fields blank for Discount Points and Lender Credits.
For Total Loan Costs; Total Points and Fees; and Origination Charges, if they are none, we are to enter "0".

Makes sense, right? frown


My co-worker heard me rant about this for about 10 minutes or so last week. smile
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#2165081 - 02/16/18 09:57 PM Re: Discount Points & Lender Credit laf0915
Red Raiders Offline
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There is so much about this new HMDA reporting that doesn't make sense. frown

ETA: When I read the initial question in this thread, I thought it said "Comic Relief" instead of "Compliance Relief". I must be HMDA loopy! smile
Last edited by Red Raiders; 02/16/18 09:59 PM.
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#2166034 - 02/27/18 07:09 PM Re: Discount Points & Lender Credit laf0915
Cheli Offline
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QuestSoft told me today that they anticipate late March for the patch work on this.

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#2166316 - 03/01/18 03:27 PM Re: Discount Points & Lender Credit David Dickinson
dutchbltz Offline
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What if the loan did not originate? I'm looking at the chart from the CFPB (and the new GIR, and the Small Entity Guide) and I'm not seeing anywhere that it spells out what to do with these fields if the application did not result in an origination. I feel it should be 'NA', since, under the section about when it should be 'NA' the first thing listed is 'applications'. I'm thinking they mean applications that did not result in originations. It also talks about how this is pursuant to 1026.38, which is the CD.... and non originated loans would not have a CD. Does anybody have any thoughts on this? I would email the CFPB on this, but I'm headed out on maternity leave literally tomorrow and I'm sure by the time they call me back I'll be long gone. ;P

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#2166318 - 03/01/18 03:40 PM Re: Discount Points & Lender Credit laf0915
David Dickinson Offline
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Central City, NE
If the loan is not originated, the answer is "NA" for Total Loan Costs, Points & Fees, Origination Charges, Discount Points & Lender Credits. All of these say "if the loan is made" in the Commentary. For instance:

Paragraph 4(a)(19)
1. Discount points—not applicable. Section 1003.4(a)(19) does not require financial institutions to report the discount points for applications, or for transactions not subject to Regulation Z, 12 CFR 1026.19(f), such as open-end lines of credit, reverse mortgages, or loans or lines of credit made primarily for business or commercial purposes. In these cases, a financial institution complies with § 1003.4(a)(19) by reporting that the requirement is not applicable to the transaction.
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#2166320 - 03/01/18 03:45 PM Re: Discount Points & Lender Credit David Dickinson
dutchbltz Offline
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Thanks - those were my thoughts too but I didn't feel 100% confident.

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#2166326 - 03/01/18 03:56 PM Re: Discount Points & Lender Credit laf0915
Dan Persfull Offline
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Bloomington, IN
From page 122 of the Oct 2017 FIG:

5) If Action Taken equals 2, 3, 4, 5, 7 or 8, then Discount Points must be NA.
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#2166330 - 03/01/18 04:12 PM Re: Discount Points & Lender Credit Dan Persfull
dutchbltz Offline
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Thank you SO MUCH! This is exactly what I was looking for.

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#2166399 - 03/01/18 08:02 PM Re: Discount Points & Lender Credit laf0915
LostinRegLand Offline
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Joined: Jun 2014
Posts: 84
WA
If you have already imported your data into Questsoft are you leaving the discount points and lender credit fields blank and living with the validity error until the fix comes through? We have already scrubbed our January data and I don't like the Dashboard screen having errors but thinking I might leave the errors until the fix comes through? How is everyone else handling this?

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#2166400 - 03/01/18 08:05 PM Re: Discount Points & Lender Credit laf0915
raitchjay Offline
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OK
I'm leaving until the fix.
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#2170296 - 03/27/18 03:32 PM Re: Discount Points & Lender Credit laf0915
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We use HMDA WIZ and I have V & Q errors (V672, V673, Q615 and Q616 and these are not on the list to be corrected in their next release) on all my TRID loans in regard to Total Points & Fees. Let's say I have a loan with $400 in Origination Charges....$1522.90 in Total Loan Cost....No Discounts Points (field is blank)....No Lender Credits (field is blank). HMDA WIZ wants me to report NA for Total Points & Fees
.
What would be the Total Points & Fees? I have 0 in the field.

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#2170300 - 03/27/18 03:35 PM Re: Discount Points & Lender Credit laf0915
raitchjay Offline
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Points & fees SHOULD be NA if you are reporting Total Loan Costs for a TRID loan. Basically, the only time you'd be reporting a number on Points & fees is for a loan subject to ATR and NOT subject to TRID (so, a mobile home only loan with no land).
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#2170308 - 03/27/18 03:42 PM Re: Discount Points & Lender Credit Compliance Newbie
RR Joker Offline
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Originally Posted By HMDA Lifer
We use HMDA WIZ and I have V & Q errors (V672, V673, Q615 and Q616 and these are not on the list to be corrected in their next release) on all my TRID loans in regard to Total Points & Fees. Let's say I have a loan with $400 in Origination Charges....$1522.90 in Total Loan Cost....No Discounts Points (field is blank)....No Lender Credits (field is blank). HMDA WIZ wants me to report NA for Total Points & Fees
.
What would be the Total Points & Fees? I have 0 in the field.


raitchjay gave you the correct answer. I don't have those V edits on mine. This field defaults to NA on TRID loans. I would caution you not to change defaults...they typically are correct [except for the "no coborrower" issues right now]
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#2170374 - 03/27/18 05:42 PM Re: Discount Points & Lender Credit laf0915
Compliance Newbie Offline
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Joker do you still have the Q616 error on these?

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#2170377 - 03/27/18 05:50 PM Re: Discount Points & Lender Credit laf0915
RR Joker Offline
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yes, which is a totally bogus Qedit.
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#2170417 - 03/27/18 06:38 PM Re: Discount Points & Lender Credit laf0915
Compliance Newbie Offline
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Great. Thanks for your help.

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#2170450 - 03/27/18 08:16 PM Re: Discount Points & Lender Credit laf0915
Dan Persfull Offline
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Bloomington, IN
Points & fees SHOULD be NA if you are reporting Total Loan Costs for a TRID loan. Basically, the only time you'd be reporting a number on Points & fees is for a loan subject to ATR and NOT subject to TRID (so, a mobile home only loan with no land).

What is this documentation for this? The loan is subject 1026.43(c).

Paragraph 4(a)(17)(ii)

1. Total points and fees—not applicable. Section 1003.4(a)(17)(ii) does not require financial institutions to report the total points and fees for transactions not subject to Regulation Z, 12 CFR 1026.43(c), such as open-end lines of credit, reverse mortgages, or loans or lines of credit made primarily for business or commercial purposes, or for applications or purchased covered loans. In these cases, a financial institution complies with § 1003.4(a)(17)(ii) by reporting that the requirement is not applicable to the transaction.

See David's post #2164812 in this thread. I agree with the opinion to report 0 when there are no points and fees.
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#2170459 - 03/27/18 08:34 PM Re: Discount Points & Lender Credit laf0915
raitchjay Offline
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OK
Paragraph 4(a)(17)(i)

1. Total loan costs—not applicable. Section 1003.4(a)(17)(i) does not require financial institutions to report the total loan costs for applications, or for transactions not subject to Regulation Z, 12 CFR 1026.43(c), and 12 CFR 1026.19(f), such as open-end lines of credit, reverse mortgages, or loans or lines of credit made primarily for business or commercial purposes. In these cases, a financial institution complies with § 1003.4(a)(17)(i) by reporting that the requirement is not applicable to the transaction.

A mobile home only loan (without land) is not subject to 1026.43 and 1026.19(f).
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#2170461 - 03/27/18 08:37 PM Re: Discount Points & Lender Credit laf0915
raitchjay Offline
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OK
Oh wait...i think i have that backwards.....that's for total loan costs, not points and fees.
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#2170462 - 03/27/18 08:39 PM Re: Discount Points & Lender Credit laf0915
Dan Persfull Offline
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That applies to Total Loan Costs, not Total Points and Fees.
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#2170464 - 03/27/18 08:40 PM Re: Discount Points & Lender Credit laf0915
raitchjay Offline
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OK
For now, all i can say is that QuestSoft is giving validity errors if you try to report numbers (including zero) for points and fees whilst also giving numbers for total loan costs. But i see your point, based on the actual commentary.
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