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#2282279 - 03/15/23 07:02 PM Does anyone use a HMDA Data Collection worksheet?
HMDA Warrior Offline
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I am working with an institution that has not previously had to file HMDA Data. They do Commercial Lending and occasionally complete loans on Multifamily Dwellings, but have always been below the volume threshold noted in § 1003.2(g)(1)(v):

(A) In each of the two preceding calendar years, originated at least 100 closed-end mortgage loans that are not excluded from this part pursuant to § 1003.3(c)(1) through (10) or (13); or

(B) In each of the two preceding calendar years, originated at least 200 open-end lines of credit that are not excluded from this part pursuant to § 1003.3(c)(1) through (10);


They will have to file HMDA Data in 2023 and we are working to get them set up for accurate data collection. I found some HMDA Data collection forms online, but they are pre-2018. The only current one I've found is the Sample Collection Form for the updated Demographic Informaiton.

Could anyone point me to a more current HMDA Data Collection form for all data fields?

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#2282284 - 03/15/23 08:26 PM Re: Does anyone use a HMDA Data Collection worksheet? HMDA Warrior
raitchjay Offline
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I'm not sure i know what a HMDA Data Collection form is if you aren't talking about DI.
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#2282285 - 03/15/23 08:33 PM Re: Does anyone use a HMDA Data Collection worksheet? HMDA Warrior
rlcarey Offline
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Might be something like this - although updated for the new HMDA: https://www.bankersonline.com/tools/42551
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#2282287 - 03/15/23 08:36 PM Re: Does anyone use a HMDA Data Collection worksheet? HMDA Warrior
rlcarey Offline
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Also HMDA Warrior, you need to be looking at the new transaction thresholds and not the old ones: https://files.consumerfinance.gov/f/documents/cfpb_hmda-transactional-coverage_2023.pdf
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#2282289 - 03/15/23 08:52 PM Re: Does anyone use a HMDA Data Collection worksheet? HMDA Warrior
HMDA Warrior Offline
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We are looking at the new thresholds, which is why the institution needs to file 2023 data. I pulled that information directly from the regulation on the CFPB website for a quick reference. They apparently have not updated the Reg yet.

This is where I pulled it from: https://www.consumerfinance.gov/rules-policy/regulations/1003/2/#g-1-v
Last edited by HMDA Warrior; 03/15/23 09:00 PM.
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#2282337 - 03/16/23 09:19 PM Re: Does anyone use a HMDA Data Collection worksheet? HMDA Warrior
TMatt87 Online
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Years ago, our FDIC examiners said HMDA collections sheets weren't good enough. We have to provide the source materials for each data point, not just a form that lists it all out. Not sure if anyone else has seen that, but we are really concerned that same thought process will carry over into 1071.
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#2282346 - 03/17/23 09:10 AM Re: Does anyone use a HMDA Data Collection worksheet? HMDA Warrior
rlcarey Offline
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The regulators and internal/external auditors are always going to compare your entries to the actual source documents rather than any checklists that might be used.
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#2282353 - 03/17/23 02:33 PM Re: Does anyone use a HMDA Data Collection worksheet? HMDA Warrior
raitchjay Offline
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I looked at the document and i really didn't get it (for the reason Randy is saying)....so you enter all the information on a piece of paper, then enter it again in your LOS or HMDA software....the piece of paper doesn't prove that anything is correct....so i struggle to see what writing it down on that piece of paper gains you. Just my opinion, and maybe i'm missing something.
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#2282358 - 03/17/23 03:09 PM Re: Does anyone use a HMDA Data Collection worksheet? HMDA Warrior
hmdagal Offline
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We have limited situations where data has to be manually entered into our HMDA software and have found that a data entry form makes the process easier and more accurate. Our forms are designed for the situation, such as loans that are repurchased, and have some fields prefilled. They're also organized in the same order as our software. We create a package that contains the form and the source documents.

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#2282362 - 03/17/23 03:42 PM Re: Does anyone use a HMDA Data Collection worksheet? HMDA Warrior
raitchjay Offline
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OK
Thanks hmdagal.....that makes sense, if designed for your software.
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#2282368 - 03/17/23 03:56 PM Re: Does anyone use a HMDA Data Collection worksheet? HMDA Warrior
Dan Persfull Offline
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that makes sense, if designed for your software.

Or small filers who input their data manually.
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#2283551 - 04/19/23 01:30 PM Re: Does anyone use a HMDA Data Collection worksheet? HMDA Warrior
dutchbltz Offline
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We have created one. Message me if you'd like and I can share a copy. Of course the intention is that there will be source material to support this information, but we will be using this to provide the info for the data entry folks.

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