This is my first time to submit HMDA data and I just received back my HMDA Edit report. We have an application that was denied basically b/c the applicant was unemployed. Unemployed = no income. The HMDA rules says that there has to be something in this field if income was considered. I just don't want this to be a red flag later...is this normal? I would think that based on the denial reason that this shouldn't show as an exception.

The edit is telling you that NA was reported in the field and if this is not correct you should make a correction. If this is correct no action is necessary. NA would be used if the decision was not based upon income, or the applicant was an employee. NA would be acceptable responses in these cases. Good luck! We're still all learning!

There are different types of Edit Checks Validity and Qualatative are ones to pay attention to. The "no income" probably has a Q in front of the edit. Its to have you look to make sure its what you want to report. You don't have to make a change.

On the other hand an Edit check with a V in front of it means you have a data conflict that needs to be resolved.

Wait a second, wait a gosh darned second! You got your edit check back and it had ONE Q error? ONE!!! ONE!!!!

I had 257 Q's. Want to trade?

Did you report income as zero or N/A? From what you've posted, I would think it should be zero, rather than N/A - i.e., you used income (or lack thereof) in your credit decision.

Thanks! I did my "HMDA Scrub" but I'll be darned if I didn't catch two mistakes after submission! Aggghhh! Then they give me only until tommorrow to fix it and I'm not sure how. I wonder if HMDAhelp responds before my deadline...I somehow doubt it.

I did not want to start a new thread - so I will ask my dumb question here (I know,there are no dumb questions, only dumb people!):

Is a cash out refinance with a Home Improvement component reported as a Refi or HI? For example, $240 goes to pay off existing loan, $60k to build new pool and the applicant indicates HI on the application.

Thanks.

Home improvement trumps refinance. This would be reported as home improvement.

You're right - there is no dumb question.

(What Skittles said Alien) The new rules are ever so confusing...but at least we got a trump list

One way to remember the trumping rule is to follow the code numbers for the loan purpose--they match the trumping rule!

1-home purchase
2-home improvement
3-refinancing

We have over 1,000 Q edits due to No Income or streamline loans or purchased loans where we chose not to report ethnicity, race, sex and income. We only have 1 actual V edit that we corrected. What now? Can we fax back the one correction? Or do we need to resubmit?

Without digging out my edit sheet, I believe as long as you have 10 or less "corrections" you can fax it back. If you have more than 10 correction then you have to resubmit.

I'm not sure if 10 is the correct number (it may be higher) but this should be explained in the documentation received with your error report.

Also, you should only have to fax back the pages with corrections. Good luck!

Question: The edit report indicates that for Q026 report N/A should be reported for: Report codes 4, 7 and 4 (not applicable) in the ethnicity, race and sex fields, respectively, for the appropriate loans on your HMDA report when:

1. Your institution purchased the loan from another institution and chose not to collect ethnicity, race and sex information.
2. The borrower or applicant is not a natural person (a corporation, for example).

I thought this was optional reporting even if we collected the information on purchased loans?

Think of a Q edit as asking the question:
"Just checking here, is this really what you want it to say?"

If you can support your decision, then the answer is "Yes" so don't worry about it.

What if we have the information but chose not to report on purchased loans? Is this acceptable?

GIR page 1-72 Applicant information may, but need not, be reported for loans purchased by the institution.

Can someone confirm this? We have a new hire that states we have to report ALL the information on purchased loans if we have it. Our manager does not want to report all the info if not required and to avoid any possible mistakes in data entry.

Sorry, the quote above was from a HMDA seminar not GIR.

The Getting It Right (GIR) should be all the confirmation that you will need. FWIW, I agree with your strategy.

Search the GIR by clicking here using purchased loans and loans purchased as your search terms.

There is mandatory data reporting and optional data reporting. The GIR will give you guidance to which is mandatory and which is optional.