HMDA 2018 Section 1003.4(a)(16) no longer provides an option to not report the denial reason that I can see.
Last edited by Dan Persfull; 02/27/19 04:38 PM.
a) Data format and itemization. A financial institution shall collect data regarding applications for covered loans that it receives, covered loans that it originates, and covered loans that it purchases for each calendar year. A financial institution shall collect data regarding requests under a preapproval program, as defined in § 1003.2(b)(2), only if the preapproval request is denied, is approved by the financial institution but not accepted by the applicant, or results in the origination of a home purchase loan. The data collected shall include the following items:
(16) The principal reason or reasons the financial institution denied the application, if applicable.
And from the 2018 GIR page 62:
5.11 Reason for denial
For an Application that it denied, a Financial Institution must report the principal reasons (up to four) that it denied the Application. 12 CFR 1003.4(a)(16); comment 4(a)(16)-1. For all other transactions, a Financial Institution reports that the data point is not applicable. Comment 4(a)(16)-4.
OOOPS. I forgot about the Interpretive Rule exempting this category for small filers.
The opinions expressed are mine and they are not to be taken as legal advice.