Frequently Asked Questions

Home Mortgage Disclosure Act (HMDA)/Reg C

Categories:

Encompass Use/Behavior Questions

Yes, Encompass will handle the HMDA Age calculation. The age calculation for fields 4183 and 4184 is based specifically on "as of the application date". It is imperative that your company has completed your HMDA Profile Settings setup to ensure you have defined the HMDA Application Date and whether or not you want to report the age(s) for Purchased Covered loans.

The rule is specific about which fields are reported for loan costs based on the LE/CD and we've repurposed existing fields to map to the HMDA screen.

Encompass will perform the required conversion to generate the required check digit.

Encompass customers will determine their borrower sets in terms of borrower and co-borrower for reporting purposes - HMDA reporting is limited to 2 persons.

Encompass currently supports both the 2017 GMI and 2018 DI. This functionality was introduced in Encompass 17.2 Release

No, not at this time. Encompass is only accommodating the reporting data fields for reverse mortgage applications so customers can decide to have one source system of record for reporting the LAR if desired. Encompass is not adding complete support for reverse mortgage loans at this time.

No Encompass will not. The commentary in the 2017 HMDA Final Rule, the bureau identifies multiple ways that relied upon credit scores might be identified. In the future we will look at some kind of configuration but at present the information can either be entered manually or through business rules.

Encompass released functionality to produce the Pipe Delimited format in the 17.3 Encompass Release. This is currently active and working.

The Red "X" on the 1003 Page 3 GMI section is required by the GSE's when collecting the Demographic Information on the 1003 Addendum.

In the HMDA Information Input screen in the Demographic Information Co-Borrower section, upon selecting the "No Co-Applicant" Field 3840 the following fields will auto populate with the No Co-Applicant reportable code.

  • Co-Borrower Age Field 4184
  • Co-BorrowerCredit Score for Decision Making Field 4177
  • Co-Borrower Credit Scoring Model Field 4178
  • Co-Borrower Ethnicity Field 4188
  • Co-Borrower Race Field 3174
  • Co-Borrower Sex Field 4189
  • Co-Borrower Ethnicity Visual Observation Field 4132
  • Co-Borrower Race Visual Observation Field 4133
  • Co-Borrower Sex Visual Observation Field 4134

No, it is recommended that setting not be turned on in a production environment earlier than 1/1/2018, however you can begin to collect the 2018 DI information prior to 1/1/2018 by selecting Field 4142 on the 1003 Page 3.

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.

Encompass has added mapping logic to these fields to auto-populate the required "NA", "8888", or "Not Applicable" data point as prescribed under the rule following the HMDA FIG reporting requirements

No, upon you selecting any of the HMDA Relied Upon DTI, CLTV, Income fields HMDA.X97, HMDA.X98, HMDA.X99, by default will populate a "NA" value to the HMDA DTI HMDA.X36, CLTV HMDA.X98 and Income HMDA.X99 fields located on the HMDA Information Input Screen.

Encompass uses the Lender credits provided to the borrower to offset closing costs that is disclosed under Line J of the Closing Cost Details page of the Closing Disclosure CD2.XSTLC. HMDA refers to 1026.38(h)(3) which are general credits and cure only.

The New 2018 HMDA forms are not currently available in the Standard Input Forms List in Input Form Builder however you can import the new HMDA forms by navigating to your local documents / forms directory.

PATH: C:\Program Files\Encompass360_17.4_2\documents\forms

NOTE: Make sure to choose the appropriate "Encompass360 folder" that retains the version where the New HMDA forms are available.

Encompass will generate a ULI using the Encompass Loan Number at the time of loan origination.



Disclaimer: These questions and answers are provided based on those received during webinars provided by the ICE Mortgage Technology Compliance Department, and those submitted to ICE Mortgage Technology directly by you. This content is intended for general information purposes with the goal of assisting ICE Mortgage Technology’s customers and non-customers, in complying with the future provisions under Regulation C (HMDA). This information is provided as a courtesy to ICE Mortgage Technology’s customers and ICE Mortgage Technology 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.