I need some help. For some reason I cannot wrap my brain around this one. The FIG shows 2 data points. 1 for Total Loan Costs and 1 for Total Points and fees. The reg used the terminology "or". The Regulatory and Reporting Overview Reference Chart also lists this as 1 data point field. So is it Total Loans Costs that need to be reported on all loans in which a CloD was issued and Total Points and Fees if a CloD was never disclosed? Is it that easy? And which is correct, the FIG or the Guide? If there are 2 fields required as the FIG lists do you just put in N/A in the alternate field?

Total Loan Costs - loans subject to TRID

Total Points and Fees - loans not subject to TRID such as a loan secured by a manufactured home only.


We enter 0 in the Total Points and Fees.

Sorry, I mistyped in my previous reply. For total points and fees we enter NA.

Thanks Dan. I have no idea why I couldn't get it. I was thinking for some reason we need to disclose fees listed don the LE for loans that a Closing Disclosure was never issued (applies to ATR but not 1026.19(f)) even though I read that was supposed to reported NA. Had me going crazy. Those 2 fields or 1 field really threw me for a loop. Thanks again.

From CFPB just in case someone else got confused like I did:

Your LAR file should include both data fields, and neither field can be left blank. However, an institution should not report a numeric value in both of these data fields.

If an institution reports a value of 0 or greater in the Total Loan Costs data field, the institution should report NA in the Total Points and Fees data field. Alternatively, if an institution reports a value of 0 or greater in the Total Points and Fees data field, the institution should report NA in the Total Loan Costs data field. In addition, an institution can report NA in both data fields if the criteria outlined in the Reportable HMDA Data: A Regulatory and Reporting Overview Reference Chart are met.

This summary might help you:

If a HMDA reportable loan is made and subject to the “ability to repay” (ATR) requirements you must report the total loan costs or the total points and fees. Report total loan costs if the loan is subject to ATR and the “integrated disclosure” (TRID) requirements. Report total points and fees if the loan is subject to ATR but not TRID. Additionally, if a HMDA reportable loan is made and subject to TRID you must also report the discount points, origination charges and lender credits.

David, on these that are reportable and subject to TRID, if any of the discount points, origination charges, or lender credits are zero - we report zero rather than NA in those fields, right?

If no points or lender credit are paid, you leave it blank.
If no origination, you enter 0

Refer to your FIG