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BankersOnline.com Forums Dodd-Frank Final Rules Discussions HMDA Overhaul 2018 Q654 - partial exemption
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#2248763 - 02/05/21 05:57 PM Q654 - partial exemption
burke116 Offline
Platinum Poster
Joined: Jun 2014
Posts: 568
Petersburg, VA
We fall under the partial exemption, however the CFPB submission is giving me the following quality error:

Q654 edits
If Income is greater than $5,000 (reported as 5) and Action Taken equals 1, 2, or 8, the DTI should generally be between 0 and 80.

I noticed that the LTV quality error Q653 includes "Exempt" as a possibility, but DTI doesn't for some reason. Did the CFPB erroneously omit Exempt as on option for the DTI quality error, or am I missing something? It's making me a bit hesitant just because there are so many errors that this one is spitting out.

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#2248766 - 02/05/21 06:46 PM Re: Q654 - partial exemption burke116
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
If you are partially exempt you should enter Exempt in that field.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2248768 - 02/05/21 06:52 PM Re: Q654 - partial exemption burke116
burke116 Offline
Platinum Poster
Joined: Jun 2014
Posts: 568
Petersburg, VA
Ok thanks, just making sure. Such a weird quality error.

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#2249176 - 02/12/21 05:12 PM Re: Q654 - partial exemption burke116
burke116 Offline
Platinum Poster
Joined: Jun 2014
Posts: 568
Petersburg, VA
For anyone looking at this thread later on, CFPB just sent this out in a "reminder and tips" email. Glad they acknowledged it and are going to fix it.

Quote
Receiving a Q654 edit? We are aware that some filers may incorrectly receive a Q654 edit when they are correctly using Exempt or NA values in the Debt-to-Income Ratio field. HMDA Operations will correct this issue shortly. If you receive Q654 and you believe that your file contains accurate DTI information, you can verify these edits and proceed to submission.

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