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#2221269 - 09/10/19 02:09 PM Points disclosed incorrectly, report HMDA?
Red Raiders Offline
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Red Raiders
Joined: May 2013
Posts: 1,054
Compliance Land
We have a loan where the lender charged 1% discount points; however, the processor put this on the wrong line in section A. Instead of being in A.01 like it should have, it was put in line A.02 and labeled Loan Origination Fee. Do we still report this on HMDA as Points? In reading the HMDA Getting It Right Guide, it states to report the total in Line A.01. Do I take the strict reading and not report this or since the intent that these were to be Points override that?
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#2221271 - 09/10/19 02:14 PM Re: Points disclosed incorrectly, report HMDA? Red Raiders
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 77,591
Galveston, TX
Sounds like you have an error on your CD and the you probably owe the borrower a new one and if moving the fee to Line 1 creates a cure - a check also.
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#2221273 - 09/10/19 02:30 PM Re: Points disclosed incorrectly, report HMDA? Red Raiders
Red Raiders Offline
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Compliance Land
Crisis averted...I think. This is actually Origination Points and not Discount Points.
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