You would think reporting the loan term (field #82) for HMDA would be fairly straightforward but it can actually be quite complicated!
If you have a closed-end loan, you can forget the odd days and just report the number of whole months between the first payment and loan maturity. Imagine you make a loan today and the first payment isn’t due for about 50 or 60 days. You start counting with that first payment. So, if you're making a 30-year loan, you'd have 360 months.
If you have an open-end line of credit, you also forget the odd days and report whole months, but you start counting from line origination to the maturity date. So, your loan term may differ depending on whether you have a loan or a line.
If we look at the next data field, the introductory rate period (#83), it doesn’t matter if it’s closed-end or open-end, you count from loan/line origination until the first rate change. So, again, you could likely have different answers for the introductory rate period than you do for the loan term.
These are the kind of things we will talk about in our upcoming webinar, HMDA: Advanced Lessons. On April 11th, we will spend two hours talking about the things that are causing the most headaches. We are going to assume that you understand HMDA and dig a little deeper at a higher level. So, we’ll get into mixed-use properties, demographic information and Reg B vs. Reg C vs. TRID when it comes to applications. We’ll also look at Reg B vs. Reg C when it comes to action taken codes and more.
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