[tressa]

It is my understanding that if a HMDA data point is reported as N/A or a code for no co-applicant and these data points are now included in the partial exemptions, you will enter the exemption codes – “Exempt” or “1111”, whichever is applicable.

For example, rate spread data point for a business loan is reported as N/A. Under the new rule it will be reported as “Exempt” instead of NA.
Next example, there is no co-applicant, credit score for co-applicant is reported as 9999. Under the new rule it will be reported as “1111”.

Is my understanding correct?

[jholzknecht]

Your understanding is correct assuming we are talking about a bank that meets all of the requirements for the EGRRCPA partial HMDA exemption.

For more information about the EGRRCPA partial HMDA exemption consider about October 1, 2018 webinar https://mycomplianceresource.com/event-registration/?ee=192.

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