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CFPB clarifies reporting requirements in new HMDA FAQs
The CFPB released two new Home Mortgage Disclosure Act FAQs in response to questions on reporting requirements for multiple data points, specifically if the information was not the dispositive factor in a credit union.
The CFPB clarifies that credit score, debt-to-income (DTI) ratio, and combined loan-to-value (CLTV) ratio when relied on in making a credit decision must be reported even if the data was not the dispositive factor.
In addition, the bureau states that when income and property value are factors in the credit decision, they too must also be reported, even if they are not the dispositive factor.
The bureau notes that specifically, for the purposes of Regulation C, it does not matter whether the application is approved or denied – all data relied on in making a credit decision must be reported.
In May, the CFPB released an updated version of its Home Mortgage Disclosure Act (HMDA) Small Entity Compliance Guide to reflect recent changes to Regulation C that increased the data reporting thresholds under HMDA; view NAFCU’s HMDA resources available to credit unions online.