10.2 HMDA Exclusions, Partial Exemptions and Data Points

Structures Excluded from Dwelling Definition

Regulation C explicitly excludes transient and non-residential properties:

• Recreational Vehicles (RVs): Campers, travel trailers, and motor homes are excluded, even if used as a primary residence.
• Houseboats and Floating Homes: Watercraft are excluded.
• Transient Housing: Hotels, motels, bed-and-breakfasts, boarding houses, dormitories, homeless shelters, and residential care facilities (nursing homes, hospices).

C. Statutory Transactional Exclusions (§1003.3(c))

The following credit transactions are expressly excluded from HMDA reporting:

1. Temporary Financing (§1003.3(c)(3)): Construction-only loans designed to be replaced by permanent financing at a later date, and bridge loans designed to be replaced by separate permanent financing for the same borrower. A short term or anticipated property sale alone does not establish temporary financing. Note: Construction-to-permanent loans that convert to long-term financing in a single close or through the same lender are reportable.
2. Agricultural Purpose Credit (§1003.3(c)(9)): Any loan or line of credit primarily for an agricultural purpose as defined in Regulation Z (§1026.3(a)).
3. Vacant Land (§1003.3(c)(2)): Loans secured solely by unimproved vacant land, even if the borrower intends to build a dwelling in the distant future (unless a construction loan contract is entered into simultaneously).
4. Purchased Loan Pools (§1003.3(c)(1)): Purchases of an interest in a pool of loans, such as mortgage-backed securities (MBS) or loan participation shares where the institution does not hold whole loan ownership.
5. Preapprovals for Open-End Lines or Home Improvement: Preapproval requests are reportable only for closed-end home purchase loans under a formal preapproval program as defined in §1003.2(b)(2).

4. Reportable Data Fields: The Expanded Dodd-Frank Roster

For covered institutions subject to full reporting, Regulation C mandates over 48 individual data points encompassing loan characteristics, pricing, risk underwriting metrics, and property attributes.

Key Data Field Categories

1. Universal Loan Identifier (ULI, §1003.4(a)(1)(i)): A unique, alphanumeric identifier assigned to each covered loan or application. The ULI cannot exceed 45 characters and must begin with the institution's 20-character Legal Entity Identifier (LEI), followed by an internal loan sequence identifier, and ending with a 2-character check-digit generated by the MOD-97-10 algorithm. It must never contain personally identifiable information (such as Social Security numbers).
2. Loan Purpose (Regulation C data requirements): Categorized as Home Purchase, Home Improvement, Refinancing, Cash-Out Refinancing, or Other.
3. Preapproval Request (Regulation C data requirements): Whether the application was a request for preapproval under a formal written preapproval program for home purchase closed-end loans.
4. Construction Method & Occupancy (§1003.4(a)(5), (6)): Construction method is recorded as Site-Built or Manufactured Home. Occupancy type is categorized as Principal Residence, Second Residence, or Investment Property.
5. Pricing Metrics:
   • Interest Rate (Regulation C data requirements): The contractual interest rate applying at closing or account opening.
   • Rate Spread (Regulation C data requirements): The difference between the loan's Annual Percentage Rate (APR) and the Average Prime Offer Rate (APOR) for a comparable transaction published weekly by the FFIEC, reportable when required by the applicable rate-spread instructions; not for every application, purchase or excluded product.
   • Total Loan Costs or Points & Fees (Regulation C data requirements): Total loan costs or total points and fees under the applicable Section 1003.4 reporting conditions; do not assume every non-TRID loan has a points-and-fees reporting duty.
   • Origination Charges, Discount Points & Lender Credits (§1003.4(a)(18)-(20)): Disclosed from the Closing Disclosure.
6. Risk and Underwriting Attributes:
   • Credit Score (Regulation C data requirements): The credit score or scores relied upon in making the credit decision, along with the commercial scoring model name.
   • Debt-to-Income (DTI) Ratio (Regulation C data requirements): The ratio of total monthly debt obligations to total monthly gross income relied upon in the underwriting decision.
   • Combined Loan-to-Value (CLTV) Ratio (Regulation C data requirements): Total debt secured by the property divided by the property's appraised value relied upon in underwriting.
   • Automated Underwriting System (AUS) Result (Regulation C data requirements): The name of the AUS used (e.g., Desktop Underwriter, Loan Product Advisor) and the system's final recommendation.
7. Non-Amortizing & Complex Loan Features (Regulation C data requirements): Flags indicating whether the loan contains balloon payments, interest-only payments, negative amortization, or other non-amortizing structures.
8. Property Value (Regulation C data requirements): The property value relied upon in generating the credit decision (appraisal or automated valuation model).

5. Institutional & Transactional Coverage Matrix

Complete the depository coverage tests

Depository coverage also requires at least one home-purchase loan, or refinancing of a home-purchase loan, secured by a first lien on a one-to-four-family dwelling in the preceding calendar year. This loan-activity test is separate from the two-year origination-volume threshold. The federal-relatedness test can be satisfied by federal insurance or regulation, or by the qualifying loan being federally insured, guaranteed or supplemented, or intended for sale to Fannie Mae or Freddie Mac. Meeting only the four items in a shortened onboarding checklist is insufficient. After establishing institutional coverage, test whether the institution meets the threshold for the particular closed-end or open-end product category and then apply transaction exclusions.