I received an email today informing me that I needed to renew my LEI for HMDA which got me thinking do we really need a LEI number and a check digit number if we qualify as a small volume originator. I know we will need an unique loan number, but do we need a LEI and check digit number?

If we don't need them, would there be any benefit to renew our number?

The LEI is still required to uniquely identify you, the lender. It replaces the RSSD number as the lender identifier for the filing. If you look at the table on page 18 of the PDF version of the 2018 HMDA Rule, or at https://www.federalregister.gov/d/2018-19244/p-85 in the online publication of the rule, you will find the LEI at the end of the right column, which lists data points that are not affected by the small reporter partial exemption.

John, i found it sort of odd that the LEI is still required....but the ULI isn't....if you have to keep your LEI, seems like you'd keep on reporting ULI's to me.

You certainly CAN continue to report ULIs, you're just not required to do so. If you choose not to report ULI, you still have to report some unique loan identifier number. For us, we are likely going to keep using the ULI generated by our loan system.

Yes i guess i just found it odd to stop requiring ULIs, but keep requiring banks to have the LEI. They go hand in hand to me.

I agree. The CFPB's "logic" is the LEI identifies the institution when they file their LAR.

Still grates me that it's a $$$$ "kaching " item.

How did they identify us before?

From the RSSD number.