Home Mortgage Disclosure Act (HMDA)/Reg C

Do we report "Loan Amount" as the "outstanding unpaid balance" not the original loan amount if we perform interim servicing until loan sold?

If you are the originating institution, the loan is a closed-end mortgage loan, and the loan is not sold to another entity during the calendar year being reported on the LAR, you will report the loan amount as stated on the legal obligation. Here is a summary of how the loan amount is reported on the LAR:

Closed Loans (Originated) -

  • Closed-End Mortgage Loan = the amount to be repaid as disclosed on the legal obligation (not including a purchased loan, an assumption, or a reverse mortgage).
  • Open-End Line of Credit = the amount of credit available to the borrower under the terms of the plan (not applicable to a reverse mortgage provided via an open-end line of credit).
  • Refinance = the amount of credit extended under the terms of the new debt obligation.
  • Assumption = the unpaid principal balance at the time of the assumption.
  • Reverse Mortgage = the initial principal limit (even if not federally insured).
  • Counteroffers (accepted) = the loan amount granted (see closed-end and open-end loan amount detail above).
  • Multiple-Purpose Loans = the entire amount of the covered loan, even if only a part of the proceeds is intended for home purchase, home improvement, or refinancing.
  • Home Improvement Loans = the entire amount of a home improvement loan, even if only a part of the proceeds is intended for home improvement.
Loan Requests Receiving Adverse Action (Applications) -
  • Counteroffers (rejected by the consumer) = the loan amount initially requested (prior to the counteroffered amount).
  • Approved But Not Accepted (including preapprovals) = the loan amount approved.
  • Denial (including preapprovals) = the loan amount for which the applicant applied.
  • Closed for Incompleteness = the loan amount for which the applicant applied.
  • Withdrawn = the loan amount for which the applicant applied.
Purchased Loans -
  • Closed-End Mortgage Loans = the unpaid principal balance at the time of purchase.
  • Open-End Line of Credit = the amount of credit available to the borrower under the terms of the plan.
Citation(s):§1003.4(a)(7); Commentary ¶4(a)(7)-1 thru -9