HMDA REFERENCE GUIDE - Sterling Compliance LLC

1 FACILITATE THOUGHT | ENGAGE DIALOGUE | ENCOURAGE SMART RISK | CULTIVATE A NETWORK | BUILD KNOWLEDGE Sterling Compliance HMDA REFERENCE GUIDE HMDA REFERENCE GUIDE IN THIS GUIDE The documents within this package were developed as we, and the industry, planned for implementation of expanded data collection and reporting requirements under the home mortgage Disclosure Act (HMDA). The documents were compiled into this GUIDE , and combined with a summary of the guidance published by the CFPB to assist you in ongoing administration and Compliance with HMDA requirements. HMDA Data Reporting Breakdown HMDA Key Fields HMDA Procedures HMDA Data Collection Checklist HMDA Demographic Collection Form HMDA: Multiple Purpose Loans Reporting NA REFERENCE GUIDE Action Taken REFERENCE GUIDE HMDA: Common Q&A CFPB HMDA Resources DATA POINTDESCRIPTIONSTATUSREGULATORY REFERENCEL egal Entity Identifier(LEI)Identifier issued to the financial institution (FI) by a utilityendorsed by the Global LEI Foundation or LEI RegulatoryOversight (a)(1)(i)(A)Universal Loan Identifier(ULI)Identifier assigned to identify and retrieve a loan or applicationthat contains the FI's LEI, an internally generated sequence ofcharacters and a check (a)(1)(i)Comments 4(a)(1)(i)-1 through 5 andAppendix CApplication DateDate the application was received or the date on the (a)(1)(ii)Comments 4(a)(1)(ii)-1 through 3 Loan TypeIndicates whether the loan or application is insured by theFederal Housing Administration, guaranteed by the VeteransAdministration, Rural Housing Service or Farm Service (a)(2)Comment 4(a)(2)

2 -1 Loan PurposeIndicates whether the transaction is for a home purchase, homeimprovement, refinancing, cash-out refinancing or (a)(3)Comments 4(a)(3)-1 through 5 PreapprovalIndicates whether the transaction involved a preapproval requestfor a home purchase loan under a preapproval (a)(4)Comments 4(a)(4)-1 and 2 Construction MethodIndicates whether the dwelling is site-built or a (a)(5)Comments 4(a)(5)-1 through 3 Occupancy TypeIndicates whether the property will be used as a principalresidence, second residence or investment (a)(6)Comments 4(a)(6)-1 through 5 Loan AmountAmount of the loan or the amount for which the (a)(7)Comments 4(a)(7)-1 through 9 Action TakenType of action taken on the loan, application or (a)(8)Comments 4(a)(8)(i)-1 through 14 and4(a)(8)(ii)-1 through 6 Action Taken DateDate of action taken on the loan, application or (a)(8)Comments 4(a)(8)(i)-1 through 14 and4(a)(8)(ii)-1 through 6 Property AddressAddress of the property securing the loan or proposed to securethe (a)(9)(i)Comments 4(a)(9)-1 through 5 and4(a)(9)(i)-1 through 3 Property LocationLocation of the property securing the loan or proposed to securethe loan by state, county and census (a)(9)(ii)Comments 4(a)(9)-1 through 5,4(a)(9)(ii)(B)-1 and 4(a)(9)(ii)(C)-1 Ethnicity, Race & SexApplicant's or borrower's ethnicity, race and sex.

3 Also, indicateswhether this information was collected by visual observation (a)(10)(i)Comments 4(a)(10)(i)-1 and 2 andAppendix BAgeApplicant's or borrower's (a)(10)(ii)Comments 4(a)(10)(ii)-1 through 5 IncomeIf credit decision is made = gross annual income relied on inmaking the credit credit decision isnot made = gross annual income relied on inprocessing the (1)(10)(iii)Comments 4(a)(10)(iii)-1 through 10 Type of PurchaserType of entity that purchased the (a)(11)Comments 4(a)(11)-1 through 10 Rate SpreadDifference between the APR and average prime offer rate for acomparable (a)(12)Comments 4(a)(12)-1 through 8 HOEPA StatusIndicates whether the loan is a high-cost mortgage under theHome Ownership and Equity Protection (13)Comment 4(a)(13)-1 Lien StatusIndicates whether the lien is a first or subordinate (a)(14)Comments 4(a)(14)-1 and 2 Credit ScoreCredit score(s) relied upon and the name and version of thecredit scoring (a)(15)Comments 4(a)(15)-1 through 7 Reason for DenialReason(s) the application was (a)(16)Comments 4(a)(16)-1 through 4 Total Loan Costs or TotalPoints & FeesEither total loan costs or total points and fees (a)(17)Comments 4(a)(17)(i)-1 through 3and 4(a)(17)(ii)-1 through 2 HMDA | REPORTABLE DATA BREAKDOWNDATA POINTDESCRIPTIONSTATUSREGULATORY REFERENCEHMDA | REPORTABLE DATA BREAKDOWNO rigination ChargesTotal borrower-paid origination (a)(18)Comments 4(a)(18)-1 through 3 Discount PointsPoints paid to the creditor to reduce the interest (a)(19)Comments 4(a)(19)-1 through 3 Lender CreditsAmount of lender (a)(20)Comments 4(a)(20)-1 through 3 Interest RateInterest rate o the approved application or (a)(21)Comments 4(a)(21)

4 -1 through 3 Prepayment Penalty TermTerm in months of any prepayment (a)(22)Comments 4(a)(22)-1 through 2 Debt-to-Income RatioRatio of the applicant's or borrower's total monthly debt to totalmonthly income relied (a)(23)Comments 4(a)(23)-1 through 7 Combined Loan-to-ValueRatioRatio of the total amount of debt that is secured by the propertyto the value of the property that was relied (a)(24)Comments 4(a)(24)-1 through 5 Loan TermNumber of months after which the legal obligation will mature (a)(25)Comments 4(a)(25)-1 through 5 Introductory Rate PeriodNumber of months until the first date the interest rate (a)(26)Comments 4(a)(26)-1 through 4 Non-Amortizing FeaturesIndicates whether the transaction involves a balloon payment,interest-only payments, negative amortization or ay other type ofnon-amortizing (a)(27)Comment 4(a)(27)-1 Property ValueValue of the property relied on that secures the (a)(28)Comments 4(a)(28)-1 through 4 Manufactured HomeSecured Property TypeIndicates whether the covered loan is secured by a manufacturedhome and land or a manufactured home with no (a)(29)Comments 4(a)(29)-1 through 4 Manufactured HomeLand Property InterestInformation about the applicant's or borrower's ownership orleasehold interest in the land where the manufactured home (a)(30)Comments 4(a)(30)-1 through 6 Total UnitsNumber of individual dwelling units related to the (31)Comments 4(a)(3)-1 through 4 Multifamily AffordableUnitsNumber of individual dwelling units related to the property thatare income-restricted under federal, state or local affordablehousing (a)(32)Comments 4(a)(32)

5 -1 through 6 Application ChannelIndicates whether the application was submitted directly to the FIand whether the obligation was initially payable to the (a)(33)Comments 4(a)(33)-1, 4(a)(33)(i)-1,and 4(a)(33)(ii)-1 through 2 mortgage LoanOriginator NMLSRI dentifierNational mortgage Licensing System Registry (NMLSR) identifierfor the (a)(34)Comments 4(a)(34)-1 through 3 Automated UnderwritingSystemName of the automated underwriting system used by the FI toevaluate the application and the result generated by that (a)(35)Comments 4(a)(35)-1 through 6 Reverse MortgageIndicates of whether the transaction is for a reverse (a)(36)Open-End Line of CreditIndicates whether the transaction is for an open-end line of (a)(37)Comment 4(a)(37)-1 Business or CommercialPurposeIndicates whether the transaction is primarily for a business orcommercial (a)(38)Comment 4(a)(38)-1 This GUIDE summarizes the requirements under HMDA and Regulation C and has primarily been derived from the CFPB's Summary of Reportable Data chart.

6 This GUIDE isintended only for a quick REFERENCE and is not a substitute for the regulation or official commentary. It does not contain information about the submission process, nor does itaddress any of the exceptions that are found in the HMDA t e r l i n g C O M P L I A N C E , LLC 1 | P a g e To evaluate financial institutions Compliance with HMDA requirements, FRB, FDIC, and OCC examination staffs will focus on the Designated Key HMDA Data Fields during transaction testing pursuant to the HMDA for data collected on or after January 1, 20181. In certain circumstances, however, consistent with the FFIEC guidelines, such examination staff may determine that it is necessary to review additional HMDA data fields, as appropriate. Field # Data Field Name Data Point Name 3 Universal Loan Identifier (ULI) Universal Loan Identifier (ULI) 4 Application Date Application Date 5 Loan Type Loan Type 6 Loan Purpose Loan Purpose 9 Occupancy Type Occupancy Type 10 Loan Amount Loan Amount 11 Action Taken Action Taken 12 Action Taken Date Action Taken Date 18 Census Tract Property Location 19 Ethnicity of Applicant or Borrower: 1 Ethnicity 25 Ethnicity of Co-Applicant or Co-Borrower: 1 Ethnicity 33 Race of Applicant or Borrower: 1 Race 34 Race of Applicant or Borrower: 2 Race 41 Race of Co-Applicant or Co-Borrower: 1 Race 42 Race of Co-Applicant or Co-Borrower.

7 2 Race 51 Sex of Applicant or Borrower Sex 52 Sex of Co-Applicant or Co-Borrower Sex 55 Age of Applicant or Borrower Age 56 Age of Co-Applicant or Co-Borrower Age 57 Income Income 61 Lien Status Lien Status 62 Credit Score of Applicant or Borrower Credit Score 1 Each agency shall operate in accordance with its supervisory authority. HMDA | DESIGNATED KEY FIELDS S t e r l i n g C O M P L I A N C E , LLC 2 | P a g e Field # Data Field Name Data Point Name 63 Credit Score of Co-Applicant or Co-Borrower Credit Score 75 Origination Charges Origination Charges 76 Discount Points Discount Points 77 Lender Credits Lender Credits 78 Interest Rate Interest Rate 80 Debt-to-Income Ratio Debt-to-Income Ratio 81 Combined Loan-To-Value Ratio Combined Loan-To-Value Ratio 82 Loan Term Loan Term 88 Property Value Property Value 89 Manufactured home Secured Property Type Manufactured home Secured Property Type 91 Total Units Total Units 102 Automated Underwriting System Result.

8 1 Automated Underwriting System 108 Reverse mortgage Reverse mortgage 109 Open-End Line of Credit Open-End Line of Credit 110 Business or Commercial Purpose Business or Commercial Purpose 1 | P a g e DATA COLLECTION The following procedures are designed to GUIDE you through the data collection process under the home mortgage Disclosure Act (HMDA) for applications received on or after January 1, 2018. HMDA Loan Application Register (LAR) data fields and their corresponding source documents have been outlined. It is critical that the source of the data for every application is consistent. The source documents listed as suggested and possible examples; your internal processes and procedures may include additional source documents not listed here. Please note that these procedures address the data collection and recording process based on the CFPB s Filing Instruction GUIDE .

9 You should document additional procedures to capture, at a minimum: How the data is actually captured within your organization ( loan officer gathering of data, HMDA worksheet, system forms, etc.); the individual(s) responsible for entering the data into your core or HMDA software; the processes you have in place to test the data; and, your submission process ( how LAR data is submitted electronically). Data Point Source Document Procedure Legal Entity Identifier (LEI) LEI Registration Call Report Enter your institution s LEI. Width specification: 20 characters Universal Loan Identifier (ULI) Internal methodology Enter the ULI for the transaction based on your internal methodology Width specification: 45 characters Once the ULI is assigned, it stays with the loan. If you purchase a covered loan, you must use the ULI that was assigned by the institution that originated the loan.

10 If no ULI was assigned by the originating institution, you assign a ULI, record and submit the transaction on your LAR. A situation like this may occur if a loan was originated prior to 1/1/2018. Application Date Uniform Residential Loan Application (1003) home Equity Application, if other than URLA Commercial Loan Application Commercial Loan Write-up Report the date the application was received. Every 1003 and home Equity application should have a received date clearly indicated by the loan officer. The application should also indicate whether it was taken by phone, in person or by fax, mail or email. Commercial loans secured by a dwelling for the purposes of purchasing, improving or refinancing the dwelling must have a clearly defined application date notated in the file. Example: 20180721 HMDA PROCEDURES 2 | P a g e Data Point Source Document Procedure For an application that was not submitted directly to you, you may report the date the application was received by the party that originally received the application, the date you received the application or the date shown on the application form.