Just want to get others perspective,on the new CFPB FAQs recently sent out on the underwriting fields in HMDA. https://www.consumerfinance.gov/pol...ments/home-mortgage-disclosure-act-faqs/
Specifically regarding CLTV, DTI, and Property Value. They seem to be differentiating between relied on and dispositive, but they don't really offer much as far as what relied on means besides that it's less than dispositive.
We generally do not report fields on denials if it didn't matter what they were in denying the application. I always read the requirement of relied on to be, it mattered in the decision (i.e. denying on credit history we don't care what your LTV/DTI are) . Does anyone think this new FAQ is inconsistent with that understanding?