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#2249363 - 02/18/21 07:40 PM Is this HMDA reportable?

Unfortunately, our online loan application system will let applicants submit a loan application without a requested dollar amount. So we have applications that the rest of the info, but no requested loan amount.

For consumer LOCs that have a purpose of "other" and no listed loan amount-- would we exclude from HMDA reporting? Most of these loan apps are almost immediately withdrawn because they meant to apply for a mortgage, not a HELOC.

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#2249407 - 02/18/21 11:29 PM Re: Is this HMDA reportable? Anonymous
rlcarey Offline
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Joined: Jul 2001
Posts: 75,723
Galveston, TX
Sounds like you have fallen on your own sword if that is not a required field. What do you do with all of these applications with no loan amount?
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2249427 - 02/19/21 02:30 PM Re: Is this HMDA reportable? Anonymous
Inherent_Risk Offline
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Joined: Jan 2017
Posts: 307
I think a lot of people on here would disagree, but I would not consider those applications. I think you could either call them prequalifications (see below) or simply say they are not made in accordance with your procedures (which would be a harder argument). Getting compliant HMDA data would be nearly impossible in these cases.

1003.2(b) - Comment 2. Prequalification. A prequalification request is a request by a prospective loan applicant (other than a request for preapproval) for a preliminary determination on whether the prospective loan applicant would likely qualify for credit under an institution's standards, or for a determination on the amount of credit for which the prospective applicant would likely qualify. Some institutions evaluate prequalification requests through a procedure that is separate from the institution's normal loan application process; others use the same process. In either case, Regulation C does not require an institution to report prequalification requests on the loan/application register, even though these requests may constitute applications under Regulation B for purposes of adverse action notices.

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