Come 2018, an institution will have to report the term of the prepayment penalty on their HMDA LAR. There are several instances where this data point should be reported as “not applicable”. This is when the application is not subject to Regulation Z, it is for a reverse mortgage, when it is a purchased loan, and if the transaction does not involve a prepayment penalty. If there is a prepayment penalty, then the term must be reported in months.
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.