17-55: New Home Mortgage Disclosure Act (HMDA) Rules

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November 16, 2017

The following are items requiring implementation under the Home Mortgage Disclosure Act - Regulation C rule changes published by the Consumer Financial protection Bureau (CFPB) which will become effective on January 1, 2018.

 

Universal Loan Identifier (ULI)

 

 For all loans closed on or after January 1, 2018, PennyMac will require the lender’s valid Universal Loan Identifier (ULI) for each loan to be provided either at registration or as part of the credit package at delivery.   The ULI must consist of the lender’s 20-digit alphanumeric Legal Entity Identifier (LEI), a loan number, up to 23 characters, unique to each covered loan application submitted from the lender, and a two-character check digit determined in accordance with guidance from the amended HMDA rules.  The ULI cannot include information that could be used to identify the applicant or borrower.  In addition, the ULI submitted to PennyMac must match the ULI reported on the Lender’s HMDA Loan Application Register (LAR) for each transaction.

 

Following is a screenshot of the registration screen where the ULI can be input:

 

 

If delivered in the credit file, the ULI should be provided in one of the following places:

 

  1. As part of a standard Loan submission form provided with every loan
  2. As part of the current Uniform Residential Loan Application (FNMA 1003, FHLMC form 65)
  3. As part of the Demographic Information Addendum (DIA).  See below for more details.

 

For non-delegated loans, as of December 22, 2017, PennyMac will require the ULI to be part of the loan registration data record at time of submission for Eligibility Review.

 

Demographic Information Addendum (DIA)

 

For all loans closed on or after January 1, 2018, a Demographic Information Addendum must be included in the closing package at delivery as a supplement to the standard 1003 application.

 

HMDA Resources

 

Additional information and HMDA Implementation guidance can be found at:

 

https://www.consumerfinance.gov/policy-compliance/guidance/implementation-guidance/hmda-implementation/

 

 

Please contact your Sales Representative with any questions.