The new HMDA data requirements under Dodd-Frank will be mandatory for loan applications taken on or after January 1, 2018.
The expanded demographic information collected and reported by lenders and individual brokers will be available to the public on the Consumer Financial Protection Bureau’s (CFPB) website.
The new Demographic Information Addendum provides expanded fields to allow the borrower to provide more detailed information regarding their ethnicity and race should they choose to do so and replaces “Section X Information for Government Monitoring Purposes” on page 4 of the 1003. A sample Addendum, with the additional fields highlighted, has been provided for reference.
Reporting requirements continue to be determined by the method of interview as detailed below.
Face-to-face Interview (including Electronic Media w/Video Component)
- Borrower Provides Information
- The borrower(s) may select as many categories and/or write in information as they choose, but they are not required to also select a sub-category.
- Select “No” under “To Be Completed by Financial Institution” section
- Borrower Does Not Wish to Provide Information
- The borrower must be advised that, due to federal regulations, the broker must note the borrower’s ethnicity, race and sex based on visual observation
- MLO must select the appropriate ethnicity, race and sex based on their visual observation from the main/aggregate categories; sub-categories are not completed by the broker.
- Select “Yes” for all questions under “To Be Completed by Financial Institution”
Telephone Interview
Brokers are responsible to explain to the borrower the purpose of the collection of demographic information as detailed on the Addendum under “Demographic Information of Borrower” topic.
- Borrower Provides Information
- The information is based on the borrowers willingness to provide
- Complete the information provided by the borrower as applicable.
- Select “Telephone Interview.”
- Borrower Does Not Wish to Provide Information
- Select “I do not wish to provide this information.”
- The broker does not complete any information not provided by the borrower during a telephone interview.
- Select “Telephone Interview.”
Fax, Mail, Email, or Internet
When an application is received via fax, mail, email, or internet the broker does not complete any information except as follows:
- If the borrower left the Addendum blank or certain sections blank select the “I do not wish to provide this information” check box as applicable
- Select “Fax or Mail” or “Email or Internet” as applicable under “The Demographic Information was provided through” topic
- The borrower can supply as much or as little information as they wish.
If you have any questions, please contact your Account Executive.