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?

I would say that if these items are in your file and a credit decision was made, they should be reported. If you're calculating an LTV or DTI, I think it's hard to say you didn't rely on it. There could be potential exceptions, such as if the applicant gave you income, but the loan program doesn't look to it at all.

However, the general rule is, even if different or additional factors ultimately led to the credit decision, these fields are to be reported.