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Financial Services Law Insights and Observations

CFPB updates HMDA FAQs

Agency Rule-Making & Guidance HMDA Underwriting Mortgages

Agency Rule-Making & Guidance

On July 28, the CFPB updated its HMDA FAQs to include new guidance covering the reporting of certain data points related to the credit decision. Specifically, the FAQs state that credit underwriting data such as credit score, debt-to-income ratio, and combined loan-to-value ratio must be reported if it was “relied on in making the credit decision—even if the data was not the dispositive factor.” Similarly, the FAQs emphasize that income and property value should also be reported if they were relied on in making the credit decision.

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