If you are a Small Filer for HMDA, there is a laundry list of data fields you are not required to report.
There are seven fields; however, that if you voluntarily report some of the information in that field, you must report all the information relative to that field. For example, if you are going to report the credit score, then you have to also report the scoring model that it came from. Just because you report the credit score, though, doesn’t mean you have to report the reasons for denial. It’s not like you’re required to go all-in on all the data. It’s just if you go in on any of those seven, then you have to give all the corresponding data for that specific field.
Check out the video as Dave gives more information on other Small Filer reporting issues. Specifically, reporting NA, reasons for denial, property address, collecting but not reporting certain fields, etc.
These are the kinds of things we will cover at our “HMDA Data for Small Filers” webinar on March 28, 2019. We’re going to spend one hour going line by line and getting into the weeds about the data you are exempt from as well as the data you’re still required to report. See you then!