HMDA/Data Collection Compliance Audit
The following checklist should be modified to fit the specifics of your institution. The auditor should have
a complete understanding of Regulation C (12 CFR 1003) and refer to the regulation, the commentary,
and the FFIEC: A Guide to HMDA Reporting: Getting It Right! for detailed explanations.
HOME MORTGAGE DISCLOSURE ACT (12 USC 2801, 12 CFR 1003)
Yes, No,
N/A
1. Does the bank collect data regarding applications
for, and originations and purchases of, home
purchase and home improvement loans
(including refinancings of both) for each calendar
year?
2. Does the bank record these transactions within 30
calendar days after the end of each calendar
quarter in which final action is taken (30 calendar
days of loan disposition for FDIC-regulated
banks)?
3. Does the loan/application register accurately
reflect the following items for each covered
application, origination, and purchase:
 An identifying number (that does not include
the applicant’s name or SSN) for the loan or
loan application? (12 CFR 1003.4(a)(1))
 The date the application was received? (12
CFR 1003.4(a)(1))
 The type of loan or application? (12 CFR
1003.4(a)(2))
 The purpose of the loan or application? (12
CFR 1003.4(a)(3))
 Whether the application is for a preapproval
and whether it resulted in a denial or an
origination? (12 CFR 1003.4(a)(4))
Work Paper
Reference
Comments
 The property type to which the loan or
application relates? (12 CFR 1003.4(a)(5))
 The owner-occupancy status of the property
to which the loan or application relates? (12
CFR 1003.4(a)(6))
 The loan amount or the amount requested on
the application? (12 CFR 1003.4(a)(7))
 The type of action taken? (12 CFR
1003.4(a)(8))
 The date such action was taken? (12 CFR
1003.4(a)(8))
 The location of the property to which the
loan or application relates by (12 CFR
1003.4(a)(9)):
— MSA or MD number (5 digits)
— State (2 digits)
— County (3 digits)
— Census tract number (6 digits)
 The ethnicity and race of the applicant or
borrower? (12 CFR 1003.4(a)(10))
The type of entity purchasing a loan that the
institution originates or purchases and then
sells within the same calendar year (this
information need not be included in quarterly
updates)? (12 CFR 1003.4(a)(11))
For originated loans subject to Regulation Z,
12 CFR 1026, the difference between the
loan's annual percentage rate (APR) and the
average prime offer rate for a comparable
transaction as of the date the interest rate is
set, if that difference is equal to or greater
than 1.5 percentage points for loans secured
by a first lien on a dwelling, or equal to or
greater than 3.5 percentage points for loans
secured by a subordinate lien on a dwelling?
(12 CFR 1003.4(a)(12))
Whether the loan is subject to the Home
Ownership and Equity Protection Act of
1994, as implemented in Regulation Z (12
CFR 1026.32)? (12 CFR 1003.4(a)(13))
The lien status of the loan or application (first
lien, subordinate lien, or not secured by a lien
on a dwelling)? (12 CFR 1003.4(a)(14))
Reasons for denial? (12 CFR 1003.4(c))
Note: This is optional information unless you
are a national bank or federally chartered
thrift.
4. If the applicant or borrower chooses not to
provide the monitoring information, does the
bank note data about the race or national origin
and sex of the applicant or borrower on the basis
of visual observation or surname to the extent
possible?
5. Does the bank exclude appropriate
applications from reporting, such as:
loan
 Loans made or purchased in a fiduciary
capacity?
 Loans on unimproved land?
 Construction loans and other temporary
financing (but construction-permanent loans
must be reported)?
 Purchase of an interest in a pool of
mortgages, such as a mortgage participation
certificate, a real estate mortgage investment
conduit (REMIC), or a mortgage-backed
security?
 Purchase solely of loan servicing rights?
 Loans originated prior to the current
reporting year and acquired as part of a
merger or acquisition, or as part of the
acquisition of all of the assets and liabilities
of a branch office?
 The acquisition of only a partial interest in a
home purchase or home improvement loan or
a refinancing by the bank, even if the bank
has participated in the underwriting and
origination of the loan (such as in certain
consortium loans)?
 Prequalification requests for mortgage loans,
as opposed to preapproval requests, which
must be reported? See 12 CFR 1003,
comment 1003.2(b)-2.
 Assumptions not involving a written
agreement between the lender and the new
borrower?
The auditor should refer to 12 CFR 1003 and FFIEC:
A Guide to HMDA Reporting: Getting It Right! for
changes made from time to time.
6. Does the bank send its complete loan/application
register to the applicable agency by March 1 of
the following year?
7. Does the bank retain a copy of each
loan/application register for a period of no less
than three years?
8. Does the bank make its mortgage loan disclosure
statement available to the public at its home
office no later than three business days after
receiving it from the Federal Financial
Institutions Examination Council (FFIEC)?
9. Does the bank make its mortgage loan disclosure
statement available to the public within 10
business days in at least one branch office in each
MSA?
10. Does the bank make its mortgage loan disclosure
statements available for five years?
11. Does the bank make its modified loan/application
register available to the public at its home office
no later than March 31 of the following year?
12. Does the bank make its modified loan/application
register available to the public in at least one
branch office in each MSA no later than March
31 of the following year?
13. Does the bank make its modified loan/application
register available for three years?
OCC-Regulated Banks — National
Fair Housing Home Loan Data System
1. If the bank receives 50 or more home loan
applications a year, as measured by the previous
calendar year, and is not covered by the Home
Mortgage Disclosure Act (HMDA), does it
record and maintain for each decision center the
following information for purchase, constructionpermanent, and refinance applications:
 Number of applications received?
 Number of loans closed?
 Number of applications denied?
 Number of loans withdrawn by the applicant?
2. Is such information updated quarterly, within 30
calendar days after the end of each calendar
quarter?
3. Does the bank attempt to obtain all of the
following information on applications for home
loans:
 Loan amount requested?
 Interest rate requested?
 Number of months requested to maturity?
 Location: complete street address, city,
county, state, and zip code?
 Number of residential units in the dwelling?
 Year the dwelling was built?
 Purpose of the loan: purchase, refinance, or
construction-permanent?
 Name and present address of the applicant?
 Age of the applicant?
 Marital status, using the categories married,
unmarried, and separated?
 Number of years applicant employed in the
present line of work or profession?
 Number of continuous years applicant
employed by the current employer?
 Gross total
applicant?
monthly
income
 Proposed monthly housing
principal, and interest?
of
each
payment,
 Purchase price?
 Total monthly payments on all outstanding
liabilities?
 Net worth?
 Date of application?
 Sex?
 Race/national origin?
4. If the applicant does not voluntarily provide the
information on sex and race/national origin, does
the bank request the applicant to note that fact,
and does the bank provide the information based
on visual observation or surname?
5. Does the bank disclose to the applicant that:
 The information on race/national origin and
sex is requested by the federal government, if
the loan is related to a home loan, to monitor
the bank's compliance with equal credit
opportunity and fair housing laws?
 The applicant is not required to furnish the
information but is encouraged to do so, and
the bank may neither discriminate on the
basis of this information nor on whether the
applicant chooses to furnish it?
 If the applicant chooses not to furnish the
information, federal regulations require the
lender to note race and sex on the basis of
visual observation or surname?
6. Does the bank maintain the following
information in each of its home loan files, as
applicable:
 Appraised value?
 Census tract number?
 Disposition of loan application?
 Final terms, if offered (even if not accepted)?
 Commitment date?
 Type of mortgage?
 Name or identification of the bank office
where the application was submitted?
 If denied, a copy of the ECOA credit notice
and statement of credit denial?
 Any additional information used by the
bank?