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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.

Can you clarify how a contractual bi-weekly loan would be disclosed for "Maturity Term"?

Revised September 30, 2016

In this case the whether the loan is originated or receives adverse action and the terms include a repayment period other than in months, the reported maturity term would be converted to an equivalent number of whole months without any remainder. Example: for a 30 year fixed rate loan using a bi-weekly repayment plan, the maturity term would still be indicated as 360 months (26 weeks per year x 30 years = 780 expected payments but the term in months would be reported as 360).

Citation(s):§1003.4(a)(25); Commentary ¶4(a)(25)-2