Under the HMDA regulation that will take effect in 2018, an institution is still required to report the lien status. This data point must be reported for loans that were originated, purchased loans, and those that did not result in origination. This includes preapprovals, denials and withdrawals.
How to determine the lien status is really up to the institution. The HMDA regulation allows the institution to use the best information that is available to them at the time final action was taken. While there is no specific method listed in the regulation, an institution can use such documents as the title search or the applicant’s credit report to determine the lien status.
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.