Clearly, you aren't making the loan without at least an estimate of value, whether it's the purchase price, a value provided by FNMA (see Truffle Royale's post ^^^) or an in-house estimate. Without it, you could not responsibly make the loan. Whatever value that is is what HMDA requires you to report.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8