HMDA compliance and reporting

Overview

The Home Mortgage Disclosure Act (HMDA) requires financial institutions to collect and report data about mortgage applications and loans. ReversePilot automates HMDA compliance for reverse mortgage lenders, handling data collection, validation, LAR (Loan Application Register) file generation, and export for submission to the Consumer Financial Protection Bureau (CFPB).

This guide walks you through the HMDA workflow in ReversePilot:

• Collecting required HMDA data fields during loan origination
• Validating data completeness before generating reports
• Generating HMDA LAR files in CFPB-compliant format
• Submitting reports to the CFPB and maintaining audit records

HMDA Data Collection

Required data points

ReversePilot automatically collects HMDA data across these categories:

• 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 during loan origination:

1. Borrower Demographics: Enter in the Borrower section
   • Race (select all that apply)
   • Ethnicity (Hispanic/Latino or Not)
   • Sex (Male, Female, or prefer not to answer)
2. Property Information: Complete in the Property section
   • Complete property address
   • Census tract (automatically determined or manually entered)
3. Loan Information: System automatically captures
   • Application date
   • Action taken
   • Loan amount
   • Loan type

Generating HMDA Reports

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 with all required data fields

Data fields in each loan record

• 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
• Other required fields per CFPB specifications

Submitting HMDA Reports

CFPB submission process

Submission deadlines

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

HMDA Required Fields

Ensure all required fields are complete before submission:

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

Common HMDA Issues

Missing Borrower Demographics

Issue: Borrower demographic information is missing or incomplete.

Solution:

1. Navigate to the Borrower section
2. Enter race, ethnicity, and sex
3. Re-validate the loan in HMDA Reporting

Missing Census Tract

Issue: Census tract is not determined or populated.

Solution:

1. Verify the property address is complete and accurate
2. The system attempts automatic determination based on the address
3. If automatic determination fails, manually enter the census tract
4. Verify the census tract accuracy before submission

Incomplete Loan Data

Issue: Required loan information is missing (application date, action taken, etc.).

Solution:

1. Complete all loan sections in the origination workflow
2. Verify application date is recorded
3. Ensure action taken is documented
4. Complete all other required fields

Best Practices

1. Collect Early: Collect HMDA data during the application process, not at closing
2. Verify Regularly: Regularly validate HMDA data completeness throughout the loan lifecycle
3. Review Before Submission: Always review HMDA reports before submitting to the CFPB
4. Maintain Records: Keep copies of all submitted reports and validation results
5. Stay Current: Keep up with HMDA regulation changes from the CFPB

Troubleshooting

Report won't generate

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

Data validation errors

• Review the validation error messages to identify which loans have issues
• Complete any missing required fields
• Verify data accuracy against source documents
• Re-validate after corrections to confirm the issues are resolved

Submission issues to CFPB

• Verify the file format is correct (should be .txt)
• Check CFPB platform requirements and any format updates
• Review the CFPB submission instructions
• Contact CFPB support if file format or validation errors persist

HMDA Resources

Regulatory resources

• CFPB HMDA Resources: Consumer Financial Protection Bureau HMDA guidance and tools
• HMDA Filing Instructions: CFPB's detailed filing instructions and data specifications
• HMDA Data Points: CFPB documentation of required data points and definitions

Internal resources

• Data Collection: Ensure HMDA data is collected during the loan origination process
• Validation Process: Use ReversePilot's validation features before generating reports
• Report Generation: Generate reports well before CFPB submission deadlines

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