Please Note That These Procedures Address the Data Collection and Recording Process Based

DATA COLLECTION
The following procedures are designed to guide you through the data collection process under the Home Mortgage Disclosure Act (HMDA)for applications receivedon or after January 1, 2018. HMDA Loan Application Register (LAR) data fields and their corresponding source documents have been outlined. It is critical that the source of the data for every application is consistent.The source documents listed as suggested and possible examples; your internal processes and procedures may include additional source documents not listed here.

Please note that these procedures address the data collection and recording process based on the CFPB’s Filing Instruction Guide. You should document additional procedures to capture, at a minimum: How the data is actually captured within your organization (e.g. loan officer gathering of data, HMDA worksheet, system forms, etc.); the individual(s) responsible for entering the data into your core or HMDA software; the processes you have in place to test the data; and, your submission process (e.g. how LAR data is submitted electronically).

Data Point / Source Document / Procedure
Legal Entity Identifier (LEI) /

• LEI Registration
• Call Report

/ Enter your institution’s LEI.
Width specification: 20 characters
Universal Loan Identifier (ULI) / Internal methodology / Enter the ULI for the transaction based on your internal methodology
Width specification: 45 characters
One the ULI is assigned, it stays with the loan.
If you previously reported a covered loan with a ULI, a financial institution that purchases that covered loan must use the ULI that was previously reported.
If you purchase a covered loan, you must use the ULI that was assigned by the institution that originated the loan.
If no ULI was assigned by the originating institution, you assign a ULI, record and submit the transaction on your LAR.
A situation like this may occur if a loan was originated prior to 1/1/2018.
Application Date /

• Uniform Residential Loan Application (1003)
• Home Equity Application, if other than URLA
• Commercial Loan Application
• Commercial Loan Write-up

/ Report the date the application was received.
Every 1003 and Home Equity application should have a received date clearly indicated by the loan officer. The application should also indicate whether it was taken by phone, in person or by fax, mail or email.
Commercial loans secured by a dwelling for the purposes of purchasing, improving or refinancing the dwelling must have a clearly defined application date notated in the file.
Example: 20180721
For an application that was not submitted directly to you, you may report the date the application was received by the party that originally received the application, the date you received the application or the date shown on the application form.
If you are treating a request to reinstate or reconsider an earlier application as a new transaction, report the date of the request as the application date. Otherwise, report the original application date.
Loan Type / Application /

1. Conventional
   Not insured or guaranteed by FHA, VA, RHS or FSA
2. Federal Housing Administration Insured (FHA)
3. Veterans Affairs Guaranteed (VA)
4. USDA Rural Housing Service or Farm Service Agency Guaranteed (RHS or FSA)

Loan Purpose /

• Application
• Commercial Loan Write-up

/

1. Home Purchase
2. Home Improvement

31. Refinancing
32. Cash-out Refinancing
4. Other Purpose
5. Not Applicable
Documentation of loan purpose within application or commercial loan write-up should be SPECIFIC.
Preapproval / File documentation of preapproval request
Formal preapproval request if applicable /

1. Preapproval requested
2. Preapproval not requested

Be sure your processes are well-defined between pre-qualifications and preapprovals. Pre-qualifications are not reportable.
Construction Method / Appraisal or evaluation /

1. Site-built
2. Manufactured Home

Modular homes and prefabricated components are reported as site-built regardless of whether they are on-frame or off-frame modular homes.
For a multi-family dwelling, report the construction method as site-built unless the multifamily dwelling is in a manufactured home community.
Occupancy Type / Application or credit write-up /

1. Principal residence
2. Second residence
3. Investment property

For HMDA reporting purposes, an applicant or borrower can have only 1 principal residence at a time. If an applicant or borrower buys or builds a new dwelling that will become the applicant’s principal residence within a year or upon the completion of construction, the new dwelling is considered the principal residence for purpose of applying this definition to a particular transaction.
A second residence is one in which the applicant will occupy the dwelling for a portion of the year and is not the applicant’s primary dwelling.
Loan Amount / Note / Enter the loan amount.
Example: 110500 or 100500.00
The field is no longer rounded
For a closed-end mortgage, other than a purchased loan, an assumption or a reverse mortgage, the amount to be repaid as disclosed on the note is the loan amount.
For purchased closed-end mortgages or an assumption for a closed-end mortgage, the unpaid principal balance at the time of the purchase or assumption is the loan amount.
For an open-end line of credit, other than a reverse mortgage open-end line of credit, the amount of credit available to the applicant is the loan amount.
For a reverse mortgage, the initial principal limit is the loan amount.
Counteroffer: If an applicant accepts a counteroffer for an amount different from the amount for which he or she initially applied, report the loan amount granted.
Multiple-Purpose Loan: Report the entire amount of the loan even if only a portion of the proceeds are being used for home purchase, home improvement or refinancing purposes.
Refinancing: Report the amount of credit extended under the new debt obligation.
Action Taken / File documentation
Note
Adverse Action Notice /

1. Loan originated
2. Application approved but not accepted
3. Application denied
4. Application withdrawn by applicant
5. File closed for incompleteness
6. Purchased loan
7. Preapproval request denied
8. Preapproval request approved but not accepted

If you purchased the loan after closing or account opening and you did not make the credit decision on the application prior to closing or account opening, report the action taken as Code 6 – Purchased Loan.
If you are repurchasing a loan from the entity to which you sold it and you made the credit decision before closing or account opening, report the action taken as Code 6 – Purchased Loan.
Approved Not Accepted: Use this code when you made a credit decision approving the application before closing or account opening, subject only to outstanding conditions that are customary commitment or closing conditions, but the applicant fails to respond to the approval or it was otherwise not consummated.
Withdrawn: Use this code only when the applicant expressly withdraws the application before you make a credit decision or before the file is closed for incompleteness.
Closed for Incompleteness: Use this code when you sent a written notice of incompleteness to which the applicant did not respond within the specified period of time. If you provide a notice of adverse action on the basis of incompleteness, you may report the action taken as either file closed for incompleteness or application denied.
Counteroffers: If the applicant does not accept the counteroffer, report is as a denial on the original terms requested. If the applicant agrees to proceed with the countered terms, report the action taken on that application.
Action Taken Date / File documentation
Note
Adverse Action Notice / Example: 20180721
Originations: Report the account opening or closing date. If the disbursement of funds is later than the closing date (e.g. upon the expiration of rescission), you may report the date of initial disbursement).
Applications Denied and Files Closed for Incompleteness: Report either the date the action was taken or the date the notice was sent to the applicant.
Withdrawn Application: Report the day the express withdrawal was received or the date shown on the notification form in the case of a written withdrawal.
Approved Not Accepted: Report any reasonable date, such as the approval date, the deadline for accepting the offer or the date the file was closed (Be Consistent inYour Approach)
Construction/Perm: Report either the closing or account opening date or the date the loan converts to permanent financing.
Loan Purchased: Report the date of purchase
Street Address / Application
Appraisal or evaluation / Report the street address including secondary address identifier.
Example: 456 W Somewhere Ave Apt 201
City / Application
Appraisal or evaluation / Report the name of the city.
Example: Anytown
State / Application
Appraisal or evaluation / Enter the 2-letter state code
Example: CA
ZIP Code / Application
Appraisal or evaluation / Enter the 5 or 9-digit ZIP code
Example: 90049-9998
Report NA if the property address is not known or the address was not provided before the loan was denied, withdrawn, or closed for incompleteness.
County / FFIEC Geocoding Site / Report the county consistent with historic geocoding rules.
Example: 06037
Census Tract / FFIEC Geocoding Site / Report the county consistent with historic geocoding rules.
Example: 0637264000
Ethnicity of Applicant or Borrower / Application or by Visual observation/surname /

1. Hispanic or Latino

11. Mexican
12. Puerto Rican
13. Cuban
14. Other Hispanic or Latino
2. Not Hispanic or Latino
3. Information not provided by applicant in mail, internet, or telephone application
4. NA
If the applicant did not select any ethnicity, but only provided ethnicity in the Free Form Text Field for Other Hispanic or Latino, either leave this data field blank or enter code 14.
Procedural Notes on Ethnicity, Race & Sex

• An applicant is not required to select an aggregate category as a precondition to selecting a subcategory.
• You should not report an aggregate category if it was not selected by the applicant.
• Do not report the ethnicity, race or sex or guarantors.
• If there are no co-applicants, you must use the corresponding codes for “No Co-Applicant.”
• If there is more than 1 co-applicant, you must report the ethnicity, race, and sex for the only the first co-applicant.
• For purchased covered loans, you may report “NA” if you choose not to report the information.
• Report “NA” for applicant and/or co-applicants that are not natural persons (LLC, corporation, partnership, etc.)
• Report BOTH the aggregate ethnicity and race categories AND the subcategories identified by the applicant.
• Preference is given to the aggregate categories. For example, if the applicant selects all 5 aggregate race categories and also selects some race subcategories, you would only report the 5 aggregate race categories.
• If the applicant chooses not to provide the information for an application taken in person, not the fact on the collection form and collect the information by visual observation or surname.
• If the applicant states on an application or orally that he or she does not wish to provide the information for an application taken by phone, you must report the code for “information not provided by applicant by mail, internet or telephone application.”

Ethnicity of Co-Applicant or Co-Borrower / Application or by Visual observation/surname /

1. Hispanic or Latino

11. Mexican
12. Puerto Rican
13. Cuban
14. Other Hispanic or Latino
2. Not Hispanic or Latino
3. Information not provided by applicant in mail, internet or telephone application
4. Not applicable
5. No co-applicant
If this data field does not contain an entry, leave it blank. If the application provided ethnicity in the Free Form Text Field for Other Hispanic or Latino and did not select Code 14, either leave the data field blank or enter Code 14.
Ethnicity of Applicant or Borrower Collected on the Basis of Visual Observation or Surname / Application or by Visual observation/surname /

1. Collected on the basis of visual observation or surname
2. Not collected on the basis of visual observation or surname
3. Not applicable

Ethnicity of Co-Applicant or Co-Borrower Collected on the Basis of Visual Observation or Surname / Application or by Visual observation/surname /

1. Collected on the basis of visual observation or surname
2. Not collected on the basis of visual observation or surname
3. Not applicable
4. No co-applicant

Race of Applicant or Borrower / Application or by Visual observation/surname /

1. American Indian or Alaska Native
2. Asian

21. Asian Indian
22. Chinese
23. Filipino
24. Japanese
25. Korean
26. Vietnamese
27. Other Asian
3. Black or African American
4. Native Hawaiian or Other Pacific Islander
41. Native Hawaiian
42. Guamanian or Chamorro
43. Samoan
44. Other Pacific Islander
5. White
6. Information not provided by applicant in mail, internet or telephone application
7. Not applicable
If the applicant or borrower did not select any race and only provide race in the Race of Applicant or Borrower Free Form Text Field for American Indian or Alaska Native Enrolled in Principal Tribe, Race of Applicant or Borrower Free Form Text Field for Other Pacific Islander, either leave this data field blank or enter, as appropriate, Code 1, 27, 44.
Race of Co-Applicant or Co-Borrower / Application or by Visual observation/surname /

1. American Indian or Alaska Native
2. Asian

21. Asian Indian
22. Chinese
23. Filipino
24. Japanese
25. Korean
26. Vietnamese
27. Other Asian
3. Black or African American
4. Native Hawaiian or Other Pacific Islander
41. Native Hawaiian
42. Guamanian or Chamorro
43. Samoan
44. Other Pacific Islander
5. White
6. Information not provided by applicant in mail, internet or telephone application
7. Not applicable
If the applicant or borrower did not select any race and only provide race in the Race of Co-Applicant or Co-Borrower Free Form Text Field for American Indian or Alaska Native Enrolled in Principal Tribe, Race of Co-Applicant or Co-Borrower Free Form Text Field for Other Pacific Islander, either leave this data field blank or enter, as appropriate, Code 1, 27, 44.
Race of Applicant or Borrower on the Basis of Visual Observation or Surname / Application or by Visual observation/surname /

1. Collected on the basis of observation or surname
2. Not collected on the basis of observation or surname
3. Not applicable

Race of Co-Applicant or Co-Borrower on the Basis of Visual Observation or Surname / Application or by Visual observation/surname /

1. Collected on the basis of observation or surname
2. Not collected on the basis of observation or surname
3. Not applicable
4. No Co-Applicant

Sex of Applicant or Borrower / Application or by Visual observation /

1. Male
2. Female
3. Information not provided by applicant in mail, internet or telephone application
4. Not applicable

6. Applicant selected both male and female
Sex of Co-Applicant or Co-Borrower / Application or by Visual observation /

1. Male
2. Female
3. Information not provided by applicant in mail, internet or telephone application
4. Not applicable
5. No Co-Applicant
6. Applicant selected both male and female

Sex of Applicant or Borrower Collected on the Basis of Visual Observation or Surname / Application or by Visual observation /

1. Collected on the basis of visual observation or surname
2. Not collected on the basis of visual observation or surname
3. Not applicable

Sex of Co-Applicant or Co-Borrower Collected on the Basis of Visual Observation or Surname / Application or by Visual observation /

1. Collected on the basis of visual observation or surname
2. Not collected on the basis of visual observation or surname
3. Not applicable
4. No Co-Applicant

Age of Applicant or Borrower / Application / Report the number of whole years from date of birth to the application date.
Example: 24
Code 8888 = Not applicable
Age of Co-Applicant or Co-Borrower / Application / Report the number of whole years from date of birth to the application date.
Example: 24
Code 8888 = Not applicable
Code 9999 = No Co-Applicant
Income / Application
Income Verification
Tax Returns
Pay Stubs
Financial Statements
Income Calculation Worksheet / Enter the gross annual income you relied on in making the credit decision.
Example: 36 or NA
Enter “NA” for non-natural person borrower.
If 2 persons jointly apply for a loan and both list income, but you only rely on the income of one of the applicants in computing ratios and evaluating creditworthiness, report only the income relied upon.
Report “NA” for a loan to an employee.
Report “NA” if income was not considered
Actual distributions from retirement accounts and other assets that you rely on as income should be reported as income.
Type of Purchaser / File documentation
Investor agreement /

1. Not applicable
   e.g. denied, withdrawn, approved not accepted, closed for incompleteness
2. Fannie Mae
3. Ginnie Mae
4. Freddie Mac
5. Farmer Mac
6. Private securitizer
7. Commercial bank, savings bank or savings association

71. Credit union, mortgage company or finance company
72. Life insurance company
8. Affiliate institution
9. Other type of purchaser
Rate Spread / FFIEC Rate Spread Calculator / Report the rate spread for ALL transactions subject to Regulation Z, not just those over the HPML threshold.
Example: 0.428 or NA
Report “NA” for assumptions, reverse mortgages, purchased loans and loans not subject to Regulation Z.
Report “NA” for loans not originated for reasons other than approved not accepted.
HOEPA Status / HOEPA Testing Worksheet /

1. High-cost mortgage
2. Not a high-cost mortgage
3. Not applicable

Lien Status / Deed
Title
Application /

1. Secured by a 1st lien
2. Secured by a subordinate lien

Report the lien status (1st or subordinate) of the property identified.
You are required to report the lien status for covered loans originated and purchased and applications that do not result in originations (e.g. preapproval requests approved not accepted, or denied; applications that are approved not accepted, denied, withdrawn or closed for incompleteness).
Procedural Notes for Credit Scores

• Report the credit score(s) relied on in making the credit decision even if it was not a dispositive factor.
• When you obtained 2+ credit scores for an individual applicant, but relied on only 1 score in making the decision, report the score actually used.
• For joint applicants, if you obtain a single credit score and rely on that credit score, report that credit score for the applicant and “NA” for the co-applicant.
• If you use more than one scoring model and combine the scores into a composite score, report that score and report that more than one scoring model was used.
• Report “NA” for transactions closed for incompleteness or withdrawn before the credit decision was made; transactions for which no credit score was relied upon; purchased covered loans; and, non-natural persons.