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Demographic Info Changes at Consummation-HMDA LAR

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For HMDA reporting purposes: An applicant's demographic information is obtained at time of application via an online application process and the data collected is the information input onto the HMDA LAR. But if the applicant changes the demographic info at consummation (at the title company) do we change the data on the LAR from the data collected at application to the data collected at consummation?

I wouldn’t. Demographic Info is to be collected at the time of application. It would be best to not even have them see a DI Form at the closing, but if they fill out new info at closing, it doesn’t override what you already have. To do otherwise, would be chaotic.

First published on 11/24/2019

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