Data Points Covered by Partial Exemptions

HMDA Alert

The Bureau of Consumer Financial Protection issued an interpretive and procedural rule on August 31, 2018, to implement and clarify section 104(a) of the Economic Growth, Regulatory Relief, and Consumer Protection Act, which amended certain provisions of the Home Mortgage Disclosure Act (HMDA). The rule allows certain insured depository institutions and insured credit unions (based on thresholds for the number of closed-end and/or open-end loans originated during a given year) to be partially exempt for certain data point reporting.  Below is a chart detailing the data points covered by the partial exemptions and the correct code to use on the HMDA LAR to signify exemption.

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Data Points Covered by Partial Exemptions

Data Points Covered by Partial Exemptions Correct Code for Exemption
§ 1003.4(a)(1)(i) – Universal Loan IdentifierUnique, within the insured depository institution, loan or application identifier that can be up to 22 characters
§ 1003.4(a)(9)(i) – Property Address (street address, city, zip code)Exempt
§ 1003.4(a)(12) – Rate SpreadExempt
§ 1003.4(a)(15) – Credit Score1111
§ 1003.4(a)(15) – Name and Version of Credit Scoring Model1111
§ 1003.4(a)(16) – Reasons for Denial1111 (Leave the remaining Reason for denial data fields blank)
§ 1003.4(a)(17) – Total Loan Costs or Total Points and FeesExempt
§ 1003.4(a)(18) – Origination ChargesExempt
§ 1003.4(a)(19) – Discount PointsExempt
§ 1003.4(a)(20) – Lender CreditsExempt
§ 1003.4(a)(21) – Interest RateExempt
§ 1003.4(a)(22) – Prepayment Penalty TermExempt
§ 1003.4(a)(23) – Debt-to-Income RatioExempt
§ 1003.4(a)(24) – Combined-Loan-to-Value RatioExempt
§ 1003.4(a)(25) – Loan TermExempt
§ 1003.4(a)(26) – Introductory Rate PeriodExempt
§ 1003.4(a)(27) – Non-Amortizing Features
Balloon Payment
Interest-Only Payment
Negative Amortization
Other Non-Amortizing Features
1111 (enter code for each one)
§ 1003.4(a)(28) – Property ValueExempt
§ 1003.4(a)(29) – Manufactured Home Secured Property Type1111
§ 1003.4(a)(30) – Manufactured Home Land Property Interest1111
§ 1003.4(a)(32) – Multifamily Affordable UnitsExempt
§ 1003.4(a)(33) – Submission of Application1111
§ 1003.4(a)(33) – Initially Payable to Your Institution 1111
§ 1003.4(a)(34) – Mortgage Loan Originator IdentifierExempt
§ 1003.4(a)(35) – Automated Underwriting System (AUS)1111 (Leave the remaining AUS blank)
§ 1003.4(a)(35) – Automated Underwriting System Result1111 (Leave the remaining AUS results blank)
§ 1003.4(a)(36) – Reverse Mortgage Flag1111
§ 1003.4(a)(37) – Open-End Line of Credit Flag1111
§ 1003.4(a)(38) – Business or Commercial Purpose Flag1111

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