CFPB adds two FAQs on HMDA reporting

The Consumer Financial Protection Bureau (CFPB) has added two frequently asked questions (FAQs) related to Home Mortgage Disclosure Act (HMDA) reporting requirements for certain data points, the agency said Thursday.

The two FAQs, dated July 28 on the agency’s website, specifically discuss reporting when the information is not the dispositive factor in a credit decision. Briefly, they conclude that:

  • Financial institutions are required to report the credit score, debt-to-income (DTI) ratio, and combined loan-to-value (CLTV) ratio relied on in making a credit decision even if that data was not the dispositive factor in a credit decision.
  • When income and property value are factors in the credit decision but not the dispositive factors, they still need to be reported.

The CFPB provides its analysis in the FAQs.

Bureau’s HMDA FAQs (click on the “multiple data points” bullet)

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