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HMDA Compliance

The Home Mortgage Disclosure Act (HMDA) requires financial institutions to collect and report data about mortgage applications and loans. This guide explains how to generate and submit HMDA reports in ReversePilot.

Overview

HMDA reporting in ReversePilot:

  • Collects required HMDA data for each loan
  • Validates data completeness
  • Generates HMDA LAR (Loan Application Register) files
  • Exports data for submission to the CFPB

HMDA Data Collection

Required Data Points

The system automatically collects HMDA data including:

  • Borrower Information: Name, race, ethnicity, sex
  • Property Information: Address, census tract, property type
  • Loan Information: Loan amount, loan type, action taken
  • Application Information: Application date, action date
  • Financial Information: Income, property value
  • Geographic Information: State, county, census tract

Data Entry

Ensure HMDA data is complete:

  1. Borrower Demographics: Enter in Borrower section
  2. Race (select all that apply)
  3. Ethnicity (Hispanic/Latino or Not)

  4. Sex (Male, Female, or prefer not to answer)

  5. Property Information: Complete Property section

  6. Complete address

  7. Census tract (automatically determined or manually entered)

  8. Loan Information: System automatically captures

  9. Application date
  10. Action taken
  11. Loan amount
  12. Loan type

Generating HMDA Reports

Step 1: Access HMDA Reporting

  1. Navigate to Reports section
  2. Select HMDA Reporting
  3. Enter reporting year
  4. Click "Validate" or "Generate Report"

Step 2: Validate Data

Before generating the report:

  1. System validates all loans for the specified year
  2. Checks for missing HMDA data
  3. Identifies data quality issues
  4. Displays validation results

Step 3: Review Validation Results

Review validation results:

  • Valid Loans: Loans with complete HMDA data
  • Invalid Loans: Loans missing required data
  • Data Issues: Specific data problems identified

Step 4: Fix Data Issues

For loans with missing data:

  1. Navigate to the loan
  2. Complete missing HMDA fields
  3. Verify data accuracy
  4. Re-validate if needed

Step 5: Generate Report

Once data is validated:

  1. Click "Generate HMDA Report"
  2. System generates LAR file
  3. File is downloaded as text file (.txt)
  4. File format complies with CFPB requirements

HMDA Report Format

File Structure

The HMDA report file contains:

  1. Header Record: Company and contact information
  2. Loan Records: One record per loan application

Data Fields

Each loan record includes:

  • Record identifier
  • Legal Entity Identifier (LEI)
  • Universal Loan Identifier (ULI)
  • Application date
  • Loan type
  • Loan purpose
  • Loan amount
  • Action taken
  • Action taken date
  • Property address
  • Census tract
  • Borrower demographics
  • And other required fields

Submitting HMDA Reports

CFPB Submission

  1. Download Report: Generate and download HMDA LAR file
  2. Review File: Verify file format and data
  3. Submit to CFPB: Upload to CFPB's HMDA Platform
  4. Verify Submission: Confirm successful submission
  5. Retain Records: Keep copies of submitted reports

Submission Deadlines

  • Annual Submission: Due by March 1 for prior year data
  • Quarterly Submission: May be required for larger institutions
  • Check Requirements: Verify your institution's requirements

HMDA Data Requirements

Required Fields

Ensure all required fields are complete:

  • Borrower demographics (race, ethnicity, sex)
  • Property address and census tract
  • Application date
  • Action taken and date
  • Loan amount
  • Loan type
  • Property type
  • And other required fields

Data Quality

Maintain data quality:

  • Verify accuracy of all data
  • Complete missing fields promptly
  • Review data before submission
  • Correct errors as needed

Common HMDA Issues

Missing Demographics

Issue: Borrower demographic information missing

Solution: 1. Navigate to Borrower section 2. Enter race, ethnicity, and sex 3. Re-validate loan

Missing Census Tract

Issue: Census tract not determined

Solution: 1. Verify property address is complete 2. System attempts automatic determination 3. Manually enter if needed 4. Verify census tract accuracy

Incomplete Loan Data

Issue: Required loan information missing

Solution: 1. Complete all loan sections 2. Verify application date 3. Ensure action taken is recorded 4. Complete all required fields

Best Practices

  1. Collect Early: Collect HMDA data during application process
  2. Verify Regularly: Regularly validate HMDA data completeness
  3. Review Before Submission: Review reports before submitting
  4. Maintain Records: Keep copies of all submitted reports
  5. Stay Current: Keep up with HMDA regulation changes

HMDA Resources

Regulatory Resources

Internal Resources

  • HMDA Data Collection: Ensure data is collected during loan process
  • Validation Process: Use system validation before generating reports
  • Report Generation: Generate reports well before submission deadline

Troubleshooting

Report Won't Generate

  • Verify you have permission to generate reports
  • Check that year parameter is valid
  • Ensure loans exist for the specified year
  • Contact administrator if issues persist

Data Validation Errors

  • Review validation error messages
  • Complete missing required fields
  • Verify data accuracy
  • Re-validate after corrections

Submission Issues

  • Verify file format is correct
  • Check CFPB platform requirements
  • Review submission instructions
  • Contact CFPB support if needed

Next Steps

For questions about HMDA reporting, contact your administrator or refer to CFPB resources.