CFPB Updates HMDA FAQs (UPDATED)

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The CFPB recently updated its Home Mortgage Disclosure Act (HMDA) FAQs to add two items regarding multiple data points.

In one FAQ, the CFPB confirms that a lender must report the credit score, debt-to-income (DTI) ratio and combined loan-to-value (CLTV) ratio if they were a factor relied on in making a credit decision, even if the data was not the dispositive factor. The CFPB provides an example of a requirement to report the consumer’s credit score when the score was relied on in making a credit decision, even if the lender denied the application because the application did not satisfy one or more underwriting requirements other than the credit score.

In the other FAQ, the CFPB advises that a lender must report the consumer’s income and the property value relied on in making a credit decision, even if they were not the dispositive factor. The CFPB explains the requirement to report the data is based on the income or property value being relied on in making the credit decision, and not whether the income or property value is a dispositive factor. The CFPB notes that under the HMDA rules, the relied-on standard applies to income and property value “in a similar way to credit score, DTI and CLTV.”

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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