On July 28, 2020, the CFPB released two new FAQs relating to the Home Mortgage disclosure Act (HMDA). This update is the second update to the CFPB’s HMDA FAQs in 2020, and the new questions covered are as follows:
Are financial institutions required to report the credit score, DTI and CLTV relied on in making a credit decision when such data is not the dispositive factor?
When income and property values are factors in the credit decision, though not the dispositive factor, should such data points be reported?
The third question was added on March 6 of 2020 and is as follows:
If a natural person applicant submits a mail, internet, or telephone application under Regulation C but does not provide race, ethnicity, or sex information, what should the financial institution report regarding whether this information was collected on the basis of visual observation or surname?
The full list of HMDA FAQs by the CFPB can be found here.