HMDA Questions
1.) My company is both a Broker and a Lender for HMDA do I need to include both Broker and Lender loans? 2.) Is there a fine for filing the HMDA data late? I ask the HMDA help desk if there was an extinsion and I was told no and if you need to file it must be by the EOB today.
There is no extension for submission of HMDA data. Reg. C requires you to update the data for the LAR a minimum of quarterly. So, by the end of the year the only data you should have to update is for the last quarter. As for brokered loans - I am assuming that the loan is brokered prior to a decision being made on it, i.e, the company in which you are brokering underwrites and makes the decision on the loan. If this is the scenario, you would not report those. Reg Z states that when a convered institution makes a loan through a third party such as a broker, the institution, rather than the third party, reports the loan if the institution makes the credit decision. Data on loan applications that do not result in an origination (closing) must be reported by the entity that makes the credit decision.