The Latest On HMDA ULI and LEI Data Points

HMDA Alert Getting It Right 2020

Assigning a Universal Loan Identifier (ULI) is the first step when it comes to reporting your HMDA data. This number is unique for each individual loan and will remain attached to the loan even if it is sold to another institution. The ULI is not just a random string of characters, it must follow a specific order as stated in Regulation C. The first part of the ULI is the Legal Entity Identifier (LEI). This is the 20-character code that is assigned to a financial institution by either The Global LEI Foundation or the LEI Regulatory Oversight Committee.

This is followed by a set of numbers that must be unique to your financial institution. This portion of the ULI can be up to 23 characters long and it can contain both numbers and letters. There is one caveat to this section however, the characters chosen cannot include any information that could identify the applicant or the borrower. For example, the applicant’s social security number, name, or the number that appears on their driver’s license cannot be used as part of the ULI.

The last portion of the ULI is a two-character check digit. The purpose of the two digits is to verify, by using a multi-step process, that the sequence of numbers and/or characters used in the ULI are correct. In order to determine what these last two characters should be, you can follow the process that is listed in Appendix C to manually generate the digits (www.consumerfinance.gov/eregulations/1003). This process can seem complicated; however, we are in luck. The CFPB has stated that they are currently in the process of creating a check digit generator that they will publish on their website at some point in the future.

For more information on HMDA regulations, 2018 data point changes or our HMDA compliance services, please call Rhonda Wannemuehler or Betsy Reynolds at 855-734-7655.

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