DATA COLLECTIONThe following procedures are designed to guide you through the data collection process under the Home Mortgage Disclosure Act (HMDA) for applications received on 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 methodologyWidth 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

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

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HMDA PROCEDURES

Data Point Source Document

Procedure

Application, if other than URLA

Commercial Loan Application

Commercial Loan Write-up

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 Purchase2. Home Improvement31. Refinancing32. Cash-out Refinancing4. Other Purpose5. Not Applicable

Documentation of loan purpose within application or commercial loan write-up should be SPECIFIC.

Preapproval File documentation of preapproval requestFormal preapproval request if applicable

1. Preapproval requested2. Preapproval not requested

Be sure your processes are well-defined between pre-qualifications and preapprovals. Pre-qualifications are not reportable.

Construction Appraisal or 1. Site-built

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Data Point Source Document

Procedure

Method evaluation 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 residence2. Second residence3. 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 100500.00The 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

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Procedure

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 documentationNoteAdverse Action Notice

1. Loan originated2. Application approved but not accepted3. Application denied4. Application withdrawn by applicant5. File closed for incompleteness6. Purchased loan7. Preapproval request denied8. 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.

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Procedure

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 documentationNoteAdverse 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 in Your 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 purchaseStreet Address Application

Appraisal or evaluation

Report the street address including secondary address identifier.Example: 456 W Somewhere Ave Apt 201

City Application Report the name of the city.

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Data Point Source Document

Procedure

Appraisal or evaluation

Example: Anytown

State Application Appraisal or evaluation

Enter the 2-letter state codeExample: CA

ZIP Code Application Appraisal or evaluation

Enter the 5 or 9-digit ZIP codeExample: 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 Latino11. Mexican12. Puerto Rican13. Cuban14. Other Hispanic or Latino2. Not Hispanic or Latino3. Information not provided by applicant in mail, internet, or telephone application4. 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

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Procedure

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 Latino11. Mexican12. Puerto Rican13. Cuban14. Other Hispanic or Latino2. Not Hispanic or Latino3. Information not provided by applicant in mail, internet or telephone application4. Not applicable5. 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 applicable4. No co-applicant

Race of Applicant Application or by 1. American Indian or Alaska Native

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Procedure

or Borrower Visual observation/surname

2. Asian21. Asian Indian22. Chinese23. Filipino24. Japanese25. Korean26. Vietnamese27. Other Asian3. Black or African American4. Native Hawaiian or Other Pacific Islander41. Native Hawaiian42. Guamanian or Chamorro43. Samoan44. Other Pacific Islander5. White6. Information not provided by applicant in mail, internet or telephone application7. 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 Native2. Asian21. Asian Indian22. Chinese23. Filipino24. Japanese25. Korean26. Vietnamese27. Other Asian3. Black or African American4. Native Hawaiian or Other Pacific Islander41. Native Hawaiian42. Guamanian or Chamorro43. Samoan44. Other Pacific Islander5. White6. Information not provided by applicant in mail, internet or telephone application

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Data Point Source Document

Procedure

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 applicable4. No Co-Applicant

Sex of Applicant or Borrower

Application or by Visual observation

1. Male2. Female3. Information not provided by applicant in

mail, internet or telephone application4. Not applicable6. Applicant selected both male and female

Sex of Co-Applicant or Co-Borrower

Application or by Visual observation

1. Male2. Female3. Information not provided by applicant in

mail, internet or telephone application4. Not applicable5. No Co-Applicant6. 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 applicable4. No Co-Applicant

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Data Point Source Document

Procedure

Age of Applicant or Borrower

Application Report the number of whole years from date of birth to the application date.Example: 24Code 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: 24Code 8888 = Not applicableCode 9999 = No Co-Applicant

Income ApplicationIncome VerificationTax ReturnsPay StubsFinancial StatementsIncome Calculation Worksheet

Enter the gross annual income you relied on in making the credit decision.Example: 36 or NAEnter “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 documentationInvestor agreement

0. Not applicablee.g. denied, withdrawn, approved not accepted, closed for incompleteness

1. Fannie Mae2. Ginnie Mae3. Freddie Mac4. Farmer Mac5. Private securitizer6. Commercial bank, savings bank or

savings association71. Credit union, mortgage company or finance company72. Life insurance company8. Affiliate institution9. 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

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Procedure

Regulation Z.

Report “NA” for loans not originated for reasons other than approved not accepted.

HOEPA Status HOEPA Testing Worksheet

1. High-cost mortgage2. Not a high-cost mortgage3. Not applicable

Lien Status DeedTitleApplication

1. Secured by a 1st lien2. 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.

Credit Score of Applicant or Borrower

Credit Report Example: 650Code 7777 = Credit score not availableCode 8888 = Not applicable

Credit Score of Co-Applicant or Co-Borrower

Credit Report Example: 650Code 7777 = Credit score not availableCode 8888 = Not applicableCode 9999 = No Co-Applicant

Applicant or Borrower, Name & Version of Credit Scoring Model

Scoring model 1. Equifax Beacon 5.02. Experian Fair Isaac3. FICO Risk Score Classic 044. FICO Risk Score Classic 98

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Data Point Source Document

Procedure

5. VantageScore 2.06. VantageScore 3.07. More than one credit scoring model 8. Other credit scoring model9. Not applicable

If Code 8 is entered, specify in text the applicant’s or borrower’s other credit scoring model. Otherwise leave the Free Form Text field blank.

Applicant or Borrower, Name & Version of Credit Scoring Model

Scoring model 1. Equifax Beacon 5.02. Experian Fair Isaac3. FICO Risk Score Classic 044. FICO Risk Score Classic 985. VantageScore 2.06. VantageScore 3.07. More than one credit scoring model 8. Other credit scoring model9. Not applicable10. No Co-Applicant

If Code 8 is entered, specify in text the co-applicant’s or co-borrower’s other credit scoring model. Otherwise leave the Free Form Text field blank.

Reason(s) for Denial File DocumentationAdverse Action Notice

1. Debt-to-Income ratioIncome insufficient for amount of credit requested, excessive obligations in relation to income

2. Employment historyTemporary or irregular employment, length of employment

3. Credit historyInsufficient # credit references, unacceptable credit references, no credit, limited credit, poor credit, etc.

4. CollateralValue or type of collateral insufficient

5. Insufficient cash (e.g. downpayment, closing costs, etc.)

6. Unverifiable informationUnable to verify credit experience, unable to verify employment, unable to verify income

7. Credit application incomplete8. Mortgage insurance denied

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9. OtherLength at residence, temporary residences, or other

10. Not applicable

Enter as many as 4 reasons for denial. If Code 9 is entered, specify in text the Other Reason for Denial. Otherwise, leave the Free Form Text Field blank.

Total Loan Costs Closing Disclosure Example: 2399.04 or NARefer to Total Loan Costs, Total Borrower-Paid Origination Charges, Total Points and Fees and Lender Credits.

Total Points and Fees

Closing Disclosure Example: 2399.04 or NARefer to Total Points and Fees.

Origination Charges

Closing Disclosure Example: 2399.04 or NARefer to Total Borrower-Paid Origination Charges.

Discount Points Closing Disclosure Example: 2399.04 or NA

Report Total Discount Points Paid.If no points were paid, leave this field blank.

Lender Credits Closing Disclosure Example: 1500.24 or NARefer to Lender Credits Issued.If no lender credits were provided, leave this field blank.

Interest Rate Note Example 4.125 or NA

Report the interest rate applicable to the approved application or to the covered loan at closing or account opening.

For applications, report interest rate only for those approved not accepted. Enter the code for “NA” for applications that are denied, withdrawn or closed for incompleteness.

Adjustable Rate – Interest Rate Unknown: If the interest rate is unknown at the time the application was approved or at closing, report the fully-index rate on the applicable index.

Prepayment Penalty Term

NoteUnderwriting Document

Example: 24 or NA

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Procedure

Debt-to-Income Ratio

Underwriting Documentation

Example: 42.95 or NA

Combined Loan-to-Value Ratio

Underwriting Documentation

Example 80.05 or NA

You are not required to rely on or calculate a combined LTV. If you did not calculate or rely on a combined LTV, report “NA.”

Loan Term Note Example: 360 or NA

Report the loan term as the scheduled number of months after which the legal obligation will mature or terminate or would have matured or terminated.

For a loan with a balloon feature, report the number of months to the final balloon payment, regardless of the amortization basis.

For an open-end line of credit with a definite term, report the number of months from account opening until the account termination date, including both the draw and repayment periods.

Introductory Rate Period

TRID DisclosuresHome Equity Loan Agreement and Disclosure

Example: 24 or NA

Report the number of months or proposed number of months in the case of an application until the first date the interest rate may change after closing or account opening.

Preferred Rates: Section 1003.4(a)(26) does not require reporting of introductory interest rate period based on preferred rates unless the terms of the legal obligation provide that the preferred rate will expire at a certain defined date.

Report “NA” for fixed rate and purchased loans.Balloon Payment Note 1. Balloon Payment

2. No Balloon PaymentInterest-Only Payments

TRID DisclosuresHome Equity Loan Agreement and Disclosure

1. Interest-only payments2. No interest-only payments

Negative Amortization

TRID DisclosuresHome Equity Loan Agreement and

1. Negative amortization2. No negative amortization

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Procedure

DisclosureOther non-Amortizing Features

TRID DisclosuresHome Equity Loan Agreement and Disclosure

1. Other non-fully amortizing features2. No other non-fully amortizing features

Property Value Appraisal or Evaluation

Example: 350500 or NA

Field is not rounded.

Report “NA” if not decision was made, even if you obtained a property value (e.g. withdrawn, closed for incompleteness).

Manufactured Home Secured Property Type

Appraisal 1. Manufactured home and land2. Manufactured home and not land3. Not applicable

Manufactured Home Land Property Interest

Appraisal 1. Direct ownership2. Indirect ownership3. Paid leasehold4. Unpaid leasehold5. Not applicable

Total Units Appraisal Example: 5Multifamily Affordable Units

Information provided by the applicant

Property valuation or inspection

Public records

Example: 5 or NA

Report the number of individuals dwelling units that are income-restricted pursuant to Federal, State or local affordable housing programs.

Submission of Application

MLO is an employee of your institution

Third party agent

1. Submitted directly to your institution2. Not submitted directly to your institution3. Not applicable

Initially Payable to your Institution

Note or loan contract

1. Initially payable to your institution2. Not initially payable to your institution3. Not applicable

Mortgage Loan Originator NMLSR Identifier

MLO ListingNMLS Consumer Access Site

Example: 123450 or NA

If the loan officer does not have an NMLS # (e.g. commercial), enter “NA”

Automated Underwriting System

Underwriting systems used

1. Desktop Underwritrer (DU)2. Loan Prospector (LP)3. Technology Open to Approved Lenders

(TOTAL) Scorecard4. Guaranteed Underwriting System (GUS)5. Other

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Procedure

6. Not applicable

Enter up to 5 AUS. If Code 5 is entered, use the Free Form Text field to specify the AUS used. Otherwise, leave the Free Form Text field blank.

AUS System Result Results provided from system

1. Approve/Eligible2. Approve/Ineligible3. Refer/Eligible4. Refer/Ineligible5. Refer with Caution6. Out of Scope7. Error8. Accept9. Caution10. Ineligible11. Incomplete12. Invalid13. Refer14. Eligible15. Unable to Determine16. Other17. Not applicable

Enter up to 5 AUS results. If Code 16 is entered, use the Free Form Text field to specify the AUS result. Otherwise, leave the Free Form Text field blank.

Reverse Mortgage Note 1. Reverse mortgage2. Not a reverse mortgage

Open-End Line of Credit

Note 1. Open-end line of credit2. Not an open-end line of credit

Business of Commercial Purpose

Credit approval memo

1. Primarily for business or commercial purpose

2. Not primarily for business or commercial purpose

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