You may have seen that the CFPB updated its HMDA Data Regulatory and Reporting Reference Chart for 2019. Changes and additions were made to reflect the updated reporting codes for the Credit Score models and Automated Underwriting System (AUS) results. Additional clarifying information was provided on those fields and a few others as well, such as:
- Report “Credit Score is not a number” (Code 7777) if your inquiry results in, for example, a “Meets Threshold” score. You should not use Code 7777 if a credit score just cannot be determined.
- Some of the credit scoring models may be referred to under different names. For example, Equifax Beacon 5.0 (Code 1) may also be known as FICO Score 5.
- If you use Freddie Mac and receive more than one result on the Feedback Certificate, report the Risk Class result.
- The HMDA Platform can accept up to 15 decimal places for both the Combined Loan-to-Value and Debt-to-Income ratios.
- A negative Debt-to-Income ratio can be reported.
In light of these revisions, we’ve also made some updates to our HMDA Data Guide. Version 3.1 is now available in our Free Lending Tools.
We also have some training opportunities coming up in March that will help you get your HMDA data as accurate as possible. Be sure to register for HMDA Demographic Information Collection (March 7th), HMDA Data for Large Filers (March 14th) and HMDA Data for Small Filers (March 28th).
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!