HMDA and Fields Tied to Regulation Z

This article should help to unravel any confusion

-- Download HMDA and Fields Tied to Regulation Z as PDF --

confusion illustration

There is a section of the revised HMDA LAR, effective 1/1/2018, that requires reporting of certain charges for consumer purpose closed end loans. The Small Entity Guide refers to these fields as “Data points for certain loans subject to Regulation Z”. On the HMDA LAR for 2018 they are fields 73 through 77.

This article and accompanying chart are my year end gift to you! On first reading, these requirements can make your head spin. The chart below illustrates what and when to report.

Four of the fields pull data from the TRID closing disclosure – Loan Costs, Borrower Paid Origination Charges, Discount Points paid to reduce the interest rate, and Lender Credits. The Points and Fees field requires reporting of points and fees calculated according to 1026.32 for consumer purpose HMDA reportable closed end loans not subject to TRID but subject to Ability to Repay.

The reportable transactions must of course be HMDA reportable.  TRID applies only to consumer purpose, closed end transactions with land as collateral. Ability to Repay applies to consumer purpose closed end loans secured by 1 to 4 family dwellings. The chart in this article reflects how the requirements are applied for HMDA reporting.

The Loan Costs and Point and Fees fields are related and apply only to closed end consumer purpose loans secured by 1 to 4 family dwellings because of the tie to Ability to Repay (1026.43(c). The Loan Cost field is tied to TRID, so will apply to those loans with land as collateral. The Points and Fees field is not related to TRID, so will apply only to those loans without land. If you report Loan Costs because there is land as collateral, you will report NA for Points and Fees.  Conversely, if you have no land as collateral, such as for a manufactured home without land, you will report NA for loan costs because the loan is not subject to TRID and instead report under points and fees.

The last three fields (Origination Charges, Discount Points, and Lender Credits) have no tie to Ability to Repay; they relate only to HMDA and TRID.

It is important to understand that 0, NA and a blank field are not equivalent on the HMDA LAR.

For loan costs, points and fees, and origination charges, report 0 if the transaction is subject to the field but there are no charges to report and report NA if the transaction is not subject to the field. Do not leave these three fields blank.

For discount points and lender credits, if the transaction is subject to reporting for the field and there is no data to report, leave the field blank – do not report 0 or NA. If the transaction is not subject to the field, report NA.

Applications that do not result in originated loans will always be reported as NA for these fields.

Purchased loans that were not originated under TRID rules (applications received prior to 10/3/2015) will always be reported as NA. Purchased loans originated under TRID rules are covered.

The following chart gives a basic overview of how this section of the HMDA LAR will work according to the Commentary and the Filing Instructions Guide (FIG).


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