HMDA Data for Large Filers

When it comes to HMDA banks that are not eligible for the partial exemption (aka large filers), there are a couple of things to keep in mind.

The first is the combined loan to value ratio (CLTV).  This ratio includes all debts and all collateral.  Imagine that you’re doing an 80/10/10 loan so the borrower can avoid PMI.  Let’s say the house is worth $100,000 and you make a first lien loan for $80,000 that will be sold on the secondary market.  You also make a $10,000 subordinate lien loan that you will keep in house.  The collateral value is $100,000 and “all debts” securing the property is $90,000.  Thus, the CLTV would be reported as .9 (90,000/100,000 = .9) for both of them. 

Let’s add another twist.  Say your loan is secured by the dwelling and some other type of collateral, like a car.  Remember, the CLTV looks at all debts and all collateral, not just the dwelling.  So, you would have to factor the value of the car into your CLTV calculation.

What gets even trickier is when you report the “Property Value” data field.  Is that based on just the value of the dwelling or is it all collateral similar to the CLTV field?  Join us on March 14, 2019, to find out the answer.  During our “HMDA Data for Large Filers” webinar, we will be walking through all the HMDA data requirements for large filers, line by line.  Find out some of the common errors and get your questions answered.  We hope to see you then!

Dave Dickinson

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