Hello, can someone please explain the 2-character digits of the ULI in plain English? It is just not soaking in for me. How do we determine what those two digits will be? Can all of our ULIs end with the same 2 digits on one LAR?

Also, do any of your banks already have an LEI? I did a search online and our community bank does not have one at this time. It appears that mainly the larger banks have them. It looks like there is an initial fee along with an annual fee, but I could not find specific amounts. Does anyone have those costs figured out?

Thank you!

I think no one has responded on this thread because its not exactly easy to put into plain English.

Essentially it is a two digit number that is mathematically generated based on the previous LEI and FI defined characters. It is designed so that at any point in the life of the loan anyone can use the math formula to verify that the LEI and FI defined characters are correct. You're best source to understand it is the commentary to the HMDA rule.

The CFPB added it based on comments received from the HMDA proposal that there would be a high risk that numbers will get inadvertently transposed (etc.) when moving the ULI from one system to another (etc.) given how long the ULI is becoming. It is a good lesson in "be careful what you wish for" as far as commenting on proposed rules go.

Nice - LOL. Well hopefully our software (QuestSoft HMDA Relief) will handle that for us! *fingers crossed*

I attended a webinar from Questsoft, and Leonard Ryan (president) indicated that they will have a tool within HMDA Relief to automatically generate the last two digits.

Yes, many of the vendors are looking at how they will handle this.