The CFPB recently updated its HMDA FAQs to emphasize that credit score(s), DTI (debt-to-income), CLTV (combined loan-to-value), income and property value MUST be reported whenever those items are relied on in making a credit decision. In other words, even if different or additional factors ultimately led to the credit decision, these fields are to be reported, when considered in your decision. Small Filers would have an exemption for these fields, except income.
HMDA continues to cause challenges! To help, we have training specific to Covered Transactions, Large Filers, Small Filers, Demographic Information, and Action Taken. Check out our Store or give us a call to see what may best fit your needs!