[jgarwood8121]

With the new HMDA rules for 2018, we are reporting the following:

1 – Home Purchase
2 – Home Improvement
3 – Refinance
4 – Other Purpose
5 – N/A

On a CRA exam that covers 2018, will the examiner’s analysis included all five categories? Four of the five? Or will the focus remain on Home Purchase, Home Improvement, and Refinance?

Specifically, I am trying to confirm if we can (or should) give credit to the business for the N/A loans.

Any thoughts?

[jholzknecht]

For CRA purposes examiners continue to consider your home mortgage, small business, small farm and consumer loans The CRA definition of home mortgage loan was revised, effective January 1, 2018, to reflect the changes in HMDA to the definitions of closed-end mortgage loan and open-end line of credit.

While the definition of home mortgage loan is now broader the expansion in home mortgage came from a contraction in consumer loans (home equity). CRA has always been broader than just home purchase, home improvement and refinance and that continues to be the case.

[Author]

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