When reporting Loan Costs, Points, Fees, Origination Charges and Lender Credits on your HMDA-LAR, there are many inconsistencies that just don’t make common sense. For instance:
1) Just because you provide a Closing Disclosure, doesn’t mean you will report these five items. If the loan were to not close for whatever reason, you would report all of these as “NA”.
2) If you are required to report these five items, and the answer is none, there are inconsistencies between these five. For Total Loan Costs, Total Points and Fees, and Origination Charges, you enter a “0”. But for Discount Points and Lender Credits, you leave the field blank.
3) If a corrected Closing Disclosure is provided to the borrower “… the financial institution reports the corrected amount…” BUT that’s only true if the corrected Closing Disclosure is provided in the same calendar year. Assume you closed a loan on December 29th and provided a corrected Closing Disclosure on January 2nd. In that case, you do not report the corrected amounts. [Commentary to §1003.4(a)(17)(i) #3, Commentary to §1003.4(a)(18) #3, Commentary to §1003.4(a)(19) #3 and Commentary to §1003.4(a)(20) #3]
We’ll be clarifying these issues and more in our HMDA Advanced Lessons webinar on May 3, 2018. Join us to get greater clarity on the many confusing HMDA issues!