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#2248950 - 02/09/21 09:35 PM HMDA Quality Edit 654
Compliance1 Offline
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Joined: Mar 2006
Posts: 623
I am in the process of checking over HMDA and scrubbing for edits. I uploaded data to the CFPB Platform and got back 98 Q654 Edits. This edit states, "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."

We are following the 2018 rule and utilizing the Exempt option for the majority of the fields...one of which is Debt-to-Income. Is anyone else receiving this edit message? And if so, how are you correcting this?

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#2248952 - 02/09/21 09:48 PM Re: HMDA Quality Edit 654 Compliance1
rlcarey Offline
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rlcarey
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Galveston, TX
If you report DTI as exempt, why would you need to do anything?
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#2248954 - 02/09/21 09:51 PM Re: HMDA Quality Edit 654 rlcarey
Compliance1 Offline
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Posts: 623
If I can report Exempt why is it giving me a quality edit? Why aren't all the other Exempt fields populating on my quality edit report? Never had this issue in the past.

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#2248957 - 02/09/21 10:02 PM Re: HMDA Quality Edit 654 Compliance1
Compliance1 Offline
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Posts: 623
I only have 132 HMDA entries with 98 of them having the Q654. So, why isn't the platform telling me that I have 132 Q654's when I am reporting Exempt in all the same fields?

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#2248977 - 02/10/21 02:08 PM Re: HMDA Quality Edit 654 Compliance1
burke116 Offline
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Posts: 529
RVA
I had the same question here: https://www.bankersonline.com/forum/ubbthreads.php/topics/2248763/q654-partial-exemption#Post2248763

I know our data was right, but it makes no sense why they wouldn't add Exempt to the quality edit criteria for DTI when they have it on everything else.

I also emailed HMDA Help and this was their response if it makes you feel better about your submission: Quality/Macroquality edits do not mean that your file is wrong, it just means that the values entered do not conform to expected values. If you believe that your file contains accurate information, you can verify these edits and proceed to submission.

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#2249014 - 02/10/21 05:29 PM Re: HMDA Quality Edit 654 burke116
Compliance1 Offline
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Joined: Mar 2006
Posts: 623
Thank you burke116 for the reassurance. I had emailed HMDA Help too but the email got sent back to me saying the address was unavailable. I do understand that these are edits that are not necessarily wrong but the whole process doesn't make sense to me. I will then verify the information and simply move forward. Thanks again.

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#2249056 - 02/10/21 09:56 PM Re: HMDA Quality Edit 654 Compliance1
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
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Bloomington, IN
why isn't the platform telling me that I have 132 Q654's when I am reporting Exempt in all the same fields?

Basically what that edit is doing is reminding you that if you are not partially exempt you need to report the DTI.
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#2249084 - 02/11/21 02:30 PM Re: HMDA Quality Edit 654 Compliance1
Inherent_Risk Offline
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Joined: Jan 2017
Posts: 307
The edit only triggers for action taken 1,2,and 8 and income over $5000. I'm guessing you had 34 entries that didn't trigger it. I agree with everyone else that you can just verify these and submit.

"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."

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#2249175 - 02/12/21 05:10 PM Re: HMDA Quality Edit 654 Compliance1
burke116 Offline
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Joined: Jun 2014
Posts: 529
RVA
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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