Home Mortgage Disclosure Act (HMDA)/Reg C

Frequently Asked Questions

Disclaimer: These questions and answers are provided based on those received during webinars provided by the Ellie Mae Compliance Department, and those submitted to Ellie Mae directly by you. This content is intended for general information purposes with the goal of assisting Ellie Mae’s customers and non-customers, in complying with the future provisions under Regulation C (HMDA). This information is provided as a courtesy to Ellie Mae’s customers and Ellie Mae makes no representation or warranty regarding the accuracy of the information set forth herein, and you may not rely on this information to ensure your company’s compliance with Regulation C (HMDA). This publication should not be construed as legal advice or opinion on any specific facts or circumstances, including the application of the HMDA regulations. You are advised to consult your own compliance staff or attorney regarding your specific residential mortgage lending questions or situation to ensure your compliance with all applicable laws and regulations.

We would like to begin using the new Demographic Information before 1/1/2018. Can we change the HMDA Admin Settings 2018 HMDA Default to a date prior to 1/1/2018?

Revised November 10, 2017

If you would like to begin collecting the 2018 DI before 1/1/2018, the recommended workflow is to use your data templates to set Field 4142 "Use 2018 DI" and leave the HMDA Admin Settings Default to 1/1/2018.

Setting the Data Template Field 4142 to "Use 2018 DI" is optional prior to 1/1/2017 and therefore there is no downside to this trigger if you start setting the flag prior to the implementation date.

Use of the HMDA Admin Setting prior to 1/1/2018 could potentially impact your loans if the disposition (Action Taken/Action Taken Date) of loans occur in 2017 since the 2018 HMDA fields have calculation specific to 2018 handling ahead of the regulation.

Citation(s):Product Specific