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Regarding the new ULI # that applies to HMDA beginning with reportable applications with action taken dates 1/1/18 or after, I have a question about the # that is unique to the institution, the number that the bank uses to identify the loan. The CFPB FIG manual states on page 49 that the # “must be unique within the financial institution”.
We would like to use loan account number. However our bank uses the same loan number on our core processing system for loan that a customer renews/refinances with us. For HMDA reporting within LaserPro software we add a digit to the loan number so that the prior loan remains within Laser Pro as well as the new loan. Does this meet the unique requirement? Does the requirement that the number be unique within the institution apply to the loan number, or does the HMDA number being unique suffice?
Under the new rule effective 1-1-18, 1003.4(a)(1)(I)(B)the ULI must include up to 23 additional characters to identify the covered loan or application, which:
(1) May be letters, numerals, or a combination of letters and numerals;
(2) Must be unique within the financial institution; and
(3) Must not include any information that could be used to directly identify the applicant or borrower…
If your system consistently adds a character to the end of the original loan number both on your core and for HMDA that should be fine. If the number doesn’t change on your core, but is changed (character added) for HMDA reporting it does not seem to meet the requirement that the number be unique within your financial institution since you are using the same number for the purchase and refi on your core.
We are hosting a HMDA webinar that will cover this on April 10. It is HMDA Implementing the New Rules Part 2 – Completing the Revised LAR and is accessible by clicking here.
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