WIXLIB

HMDA PROCEDURESDATA COLLECTIONThe following procedures are designed to guide you through the data collection process under the HomeMortgage Disclosure Act (HMDA) for applications received on or after January 1, 2018. HMDA LoanApplication Register (LAR) data fields and their corresponding source documents have been outlined. It iscritical that the source of the data for every application is consistent. The source documents listed assuggested and possible examples; your internal processes and procedures may include additional sourcedocuments not listed here.Please note that these procedures address the data collection and recording process based on the CFPB’s FilingInstruction Guide. You should document additional procedures to capture, at a minimum: How the data is actuallycaptured within your organization (e.g. loan officer gathering of data, HMDA worksheet, system forms, etc.); theindividual(s) responsible for entering the data into your core or HMDA software; the processes you have in place totest the data; and, your submission process (e.g. how LAR data is submitted electronically).Data PointSource DocumentProcedureLegal Entity Identifier(LEI) LEI Registration Call ReportEnter your institution’s LEI.Width specification: 20 charactersUniversal LoanIdentifier (ULI)Internal methodologyEnter the ULI for the transaction based on your internalmethodologyWidth specification: 45 charactersOnce the ULI is assigned, it stays with the loan.If you purchase a covered loan, you must use the ULI that wasassigned by the institution that originated the loan.If no ULI was assigned by the originating institution, youassign a ULI, record and submit the transaction on your LAR.A situation like this may occur if a loan was originated prior to1/1/2018.Application Date Uniform ResidentialLoan Application(1003) Home EquityApplication, if otherthan URLA Commercial LoanApplication Commercial LoanWrite-upReport the date the application was received.Every 1003 and Home Equity application should have areceived date clearly indicated by the loan officer. Theapplication should also indicate whether it was taken byphone, in person or by fax, mail or email.Commercial loans secured by a dwelling for the purposes ofpurchasing, improving or refinancing the dwelling must have aclearly defined application date notated in the file.Example: 201807211 Page

Data PointSource DocumentProcedureFor an application that was not submitted directly to you, youmay report the date the application was received by the partythat originally received the application, the date you receivedthe application or the date shown on the application form.For a request to reinstate or reconsider an earlier applicationas a new transaction, report the date of the request as theapplication date. Otherwise, report the original applicationdate.Loan TypeLoan PurposeApplication1.ConventionalNot insured or guaranteed by FHA, VA, RHS or FSA Application Commercial LoanWrite-up2.3.4.Federal Housing Administration Insured (FHA)Veterans Affairs Guaranteed (VA)USDA Rural Housing Service or Farm Service AgencyGuaranteed (RHS or FSA)1.2.31.32.4.5.Home PurchaseHome ImprovementRefinancingCash-out RefinancingOther PurposeNot ApplicableDocumentation of loan purpose within application orcommercial loan write-up should be SPECIFIC.PreapprovalConstruction MethodFile documentation ofpreapproval requestFormal preapprovalrequest if applicableAppraisal or evaluation1.2.Preapproval requestedPreapproval not requestedBe sure your processes are well-defined between prequalifications and preapprovals. Pre-qualifications are notreportable.1.2.Site-builtManufactured HomeModular homes and prefabricated components are reportedas site-built regardless of whether they are on-frame or offframe modular homes.For a multi-family dwelling, report the construction methodas site-built unless the multifamily dwelling is in amanufactured home community.Occupancy TypeApplication or creditwrite-up1.2.3.Principal residenceSecond residenceInvestment property2 Page

Data PointSource DocumentProcedureFor HMDA reporting purposes, an applicant or borrower canhave only 1 principal residence at a time. If an applicant orborrower buys or builds a new dwelling that will become theapplicant’s principal residence within a year or upon thecompletion of construction, the new dwelling is consideredthe principal residence for purpose of applying this definitionto a particular transaction.A second residence is one in which the applicant will occupythe dwelling for a portion of the year and is not theapplicant’s primary dwelling.An investment property is any property that is not theapplicant’s primary or secondary residence.Loan AmountNoteEnter the loan amount.Example: 110500 or 100500.00The field is no longer roundedFor a closed-end mortgage, other than a purchased loan, anassumption or a reverse mortgage, the amount to be repaidas disclosed on the Promissory Note is the loan amount.For purchased closed-end mortgages or an assumption for aclosed-end mortgage, the unpaid principal balance at thetime of the purchase or assumption is the loan amount.For an open-end line of credit, other than a reverse mortgageopen-end line of credit, the amount of credit available to theapplicant is the loan amount.For a reverse mortgage, the initial principal limit is the loanamount.Counteroffer: If an applicant accepts a counteroffer for anamount different from the amount for which he or sheinitially applied, report the loan amount granted. Ifcounteroffer is not accepted, report the amount originallyrequested.Multiple-Purpose Loan: Report the entire amount of the loaneven if only a portion of the proceeds are being used forhome purchase, home improvement or refinancing purposes.Refinancing: Report the amount of credit extended under thenew debt obligation.Action TakenFile documentation1.Loan originated3 Page

Data PointSource DocumentNoteAdverse Action NoticeProcedure2.3.4.5.6.7.8.Application approved but not acceptedApplication deniedApplication withdrawn by applicantFile closed for incompletenessPurchased loanPreapproval request deniedPreapproval request approved but not acceptedIf you purchased the loan after closing or account openingand you did not make the credit decision on the applicationprior to closing or account opening, report the action taken asCode 6 – Purchased Loan.If you are repurchasing a loan from the entity to which yousold it and you made the credit decision before closing oraccount opening, report the action taken as Code 6 –Purchased Loan.Approved Not Accepted: Use this code when you made acredit decision approving the application before closing oraccount opening, subject only to outstanding conditions thatare customary commitment or closing conditions, but theapplicant fails to respond to the approval or it was otherwisenot consummated.Withdrawn: Use this code only when the applicant expresslywithdraws the application before you make a credit decisionor before the file is closed for incompleteness.Closed for Incompleteness: Use this code when you sent awritten notice of incompleteness to which the applicant didnot respond within the specified period of time. If youprovide a notice of adverse action on the basis ofincompleteness, you may report the action taken as either fileclosed for incompleteness or application denied.Counteroffers: If the applicant does not accept thecounteroffer, report is as a denial on the original termsrequested. If the applicant agrees to proceed with thecountered terms, report the action taken as originated, orapproved but not accepted if the loan does not ultimatelyclose.Action Taken DateFile documentationNoteAdverse Action NoticeExample: 20180721Originations: Report the account opening or closing date. Ifthe disbursement of funds is later than the closing date (e.g.upon the expiration of rescission), you may report the date ofinitial disbursement).4 Page

Data PointSource DocumentProcedureApplications Denied and Files Closed for Incompleteness:Report either the date the action was taken or the date thenotice was sent to the applicant.Withdrawn Application: Report the day the expresswithdrawal was received or the date shown on thenotification form in the case of a written withdrawal.Approved Not Accepted: Report any reasonable date, such asthe approval date, the deadline for accepting the offer or thedate the file was closed (Be Consistent in Your Approach)Construction/Perm: Report either the closing or accountopening date or the date the loan converts to permanentfinancing.Loan Purchased: Report the date of purchaseStreet AddressApplicationAppraisal or evaluationReport the street address including secondary addressidentifier. Cannot be a PO Box.Example: 456 W Somewhere Ave Apt 201CityApplicationAppraisal or evaluationReport the name of the city.Example: AnytownStateApplicationAppraisal or evaluationEnter the 2-letter state codeExample: CAZIP CodeApplicationAppraisal or evaluationEnter the 5 or 9-digit ZIP codeExample: 90049-9998Report NA if the property address is not known or the addresswas not provided before the loan was denied, withdrawn, orclosed for incompleteness.CountyFFIEC Geocoding SiteReport the county consistent with historic geocoding rules.Example: 06037Census TractFFIEC Geocoding SiteReport the county consistent with historic geocoding rules.Example: 0637264000Ethnicity of Applicantor BorrowerApplication or by Visualobservation/surname1. Hispanic or Latino11. Mexican12. Puerto Rican13. Cuban14. Other Hispanic or Latino2. Not Hispanic or Latino3. Information not provided by applicant in mail,internet, or telephone application4. NA5 Page

Data PointSource DocumentProcedureIf the applicant did not select any ethnicity, but only providedethnicity in the Free Form Text Field for Other Hispanic orLatino, either leave this data field blank or enter code 14.Procedural Notes on Ethnicity, Race & Sex An applicant is not required to select an aggregate category as a precondition to selecting a subcategory. You should not report an aggregate category if it was not selected by the applicant. Do not report the ethnicity, race or sex or guarantors. If there are no co-applicants, you must use the corresponding codes for “No Co-Applicant.” If there is more than 1 co-applicant, you must report the ethnicity, race, and sex for the only the first coapplicant. For purchased covered loans, you may report “NA” if you choose not to report the information. Report “NA” for applicant and/or co-applicants that are not natural persons (LLC, corporation, partnership,etc.) Report BOTH the aggregate ethnicity and race categories AND the subcategories identified by the applicant. Preference is given to the aggregate categories. For example, if the applicant selects all 5 aggregate racecategories and also selects some race subcategories, you would only report the 5 aggregate race categories. If the applicant chooses not to provide the information for an application taken in person, not the fact on thecollection form and collect the information by visual observation or surname. If the applicant states on an application or orally that he or she does not wish to provide the information for anapplication taken by phone, you must report the code for “information not provided by applicant by mail,internet or telephone application.”Ethnicity of CoApplicant or CoBorrowerApplication or by Visualobservation/surname1. Hispanic or Latino11. Mexican12. Puerto Rican13. Cuban14. Other Hispanic or Latino*2. Not Hispanic or Latino3. Information not provided by applicant in mail, internetor telephone application4. Not applicable5. No co-applicant*If this data field does not contain an entry, leave it blank. Ifthe applicant provided ethnicity in the Free Form Text Fieldfor Other Hispanic or Latino and did not select Code 14, eitherleave the data field blank or enter Code 14.Ethnicity of Applicantor Borrower Collectedon the Basis of VisualApplication or by Visualobservation/surname1.2.Collected on the basis of visual observation orsurnameNot collected on the basis of visual observation orsurname6 Page

Data PointSource DocumentObservation orSurnameEthnicity of CoApplicant or CoBorrower Collected onthe Basis of VisualObservation orSurnameApplication or by Visualobservation/surnameRace of Applicant orBorrowerApplication or by Visualobservation/surnameProcedure3.Not applicable1.Collected on the basis of visual observation orsurnameNot collected on the basis of visual observation orsurnameNot applicableNo co-applicant2.3.4.1. American Indian or Alaska Native*2. Asian21. Asian Indian22. Chinese23. Filipino24. Japanese25. Korean26. Vietnamese27. Other Asian3. Black or African American4. Native Hawaiian or Other Pacific Islander41. Native Hawaiian42. Guamanian or Chamorro43. Samoan44. Other Pacific Islander*5. White6. Information not provided by applicant in mail,internet or telephone application7. Not applicableIf the applicant did not enter anything in the free-form textfield, either leave this data field blank or enter, asappropriate, Code 1, 27, 44.Race of Co-Applicant orCo-BorrowerApplication or by Visualobservation/surname1. American Indian or Alaska Native*2. Asian21. Asian Indian22. Chinese23. Filipino24. Japanese25. Korean26. Vietnamese27. Other Asian3. Black or African American4. Native Hawaiian or Other Pacific Islander7 Page

Data PointSource DocumentProcedure41. Native Hawaiian42. Guamanian or Chamorro43. Samoan44. Other Pacific Islander*5. White6. Information not provided by applicant in mail,internet or telephone application7. Not applicableIf the co-applicant did not enter anything in the free-form textfield, either leave this data field blank or enter, asappropriate, Code 1, 27, 44.Race of Applicant orBorrower on the Basisof Visual Observationor SurnameApplication or by Visualobservation/surname1.2.3.Collected on the basis of observation or surnameNot collected on the basis of observation or surnameNot applicableRace of Co-Applicant orCo-Borrower on theBasis of VisualObservation orSurnameApplication or by Visualobservation/surname1.2.3.4.Collected on the basis of observation or surnameNot collected on the basis of observation or surnameNot applicableNo Co-ApplicantSex of Applicant orBorrowerApplication or by Visualobservation1.2.3.MaleFemaleInformation not provided by applicant in mail,internet or telephone applicationNot applicableApplicant selected both male and female4.6.Sex of Co-Applicant orCo-BorrowerApplication or by Visualobservation1.2.3.4.5.6.Sex of Applicant orBorrower Collected onthe Basis of VisualObservation orSurnameApplication or by Visualobservation1.2.3.MaleFemaleInformation not provided by applicant in mail,internet or telephone applicationNot applicableNo Co-ApplicantApplicant selected both male and femaleCollected on the basis of visual observation orsurnameNot collected on the basis of visual observation orsurnameNot applicable8 Page

Data PointSource DocumentProcedureSex of Co-Applicant orCo-Borrower Collectedon the Basis of VisualObservation orSurnameApplication or by VisualobservationAge of Applicant orBorrowerApplication, CIPReport the number of whole years from date of birth to theapplication date.Example: 24Code 8888 Not applicableAge of Co-Applicant orCo-BorrowerApplication, CIPReport the number of whole years from date of birth to theapplication date.Example: 24Code 8888 Not applicableCode 9999 No Co-ApplicantIncomeApplicationIncome VerificationTax ReturnsPay StubsFinancial StatementsIncome CalculationWorksheetEnter the gross annual income you relied on in making thecredit decision.Example: 36 or NAEnter “NA” for non-natural person borrower.If 2 persons jointly apply for a loan and both list income, butyou only rely on the income of one of the applicants incomputing ratios and evaluating creditworthiness, report onlythe income relied upon.Report “NA” for a loan to an employee.Report “NA” if income was not considered1.2.3.4.Collected on the basis of visual observation orsurnameNot collected on the basis of visual observation orsurnameNot applicableNo Co-ApplicantActual distributions from retirement accounts and otherassets that you rely on as income should be reported asincome.Type of PurchaserFile documentationInvestor agreement0.1.2.3.4.5.6.71.72.8.9.Not applicablee.g. denied, withdrawn, approved not accepted,closed for incompletenessFannie MaeGinnie MaeFreddie MacFarmer MacPrivate securitizerCommercial bank, savings bank or savingsassociationCredit union, mortgage company or finance companyLife insurance companyAffiliate institutionOther type of purchaser9 Page

Data PointSource DocumentProcedureRate SpreadFFIEC Rate SpreadCalculatorReport the rate spread for ALL transactions subject toRegulation Z, not just those over the HPML threshold.Example: 0.428 or NAReport “NA” for assumptions, reverse mortgages, purchasedloans and loans not subject to Regulation Z.Report “NA” for loans not originated for reasons other thanapproved not accepted.HOEPA StatusHOEPA TestingWorksheet1.2.3.High-cost mortgageNot a high-cost mortgageNot applicableLien StatusTitle policy, propertyreport or application1.2.Secured by a 1st lienSecured by a subordinate lienReport the lien status (1st or subordinate) of the propertyidentified.You are required to report the lien status for covered loansoriginated and purchased and applications that do not resultin originations (e.g. preapproval requests approved notaccepted, or denied; applications that are approved notaccepted, denied, withdrawn or closed for incompleteness).Procedural Notes for Credit Scores Report the credit score(s) relied on in making the credit decision even if it was not the dispositive factor. When you obtained 2 credit scores for an individual applicant, but relied on only 1 score in making thedecision, report the score relied on. For joint applicants, if you obtain a single credit score and rely on that credit score, report that credit score forthe applicant and “NA” for the co-applicant. If you use more than one scoring model and combine the scores into a composite score, report that score andreport that more than one scoring model was used. Report “NA” for transactions closed for incompleteness or withdrawn before the credit decision was made;transactions for which no credit score was relied upon; purchased covered loans; and, non-natural persons.Credit Score ofApplicant or BorrowerCredit ReportExample: 650Code 7777 Credit score not availableCode 8888 Not applicableCredit Score of CoApplicant or CoBorrowerCredit ReportExample: 650Code 7777 Credit score not availableCode 8888 Not applicableCode 9999 No Co-Applicant10 P a g e

Data PointSource DocumentApplicant or Borrower,Name & Version ofCredit Scoring ModelScoring modelProcedure1.2.3.4.5.6.7.8.9.Equifax Beacon 5.0Experian Fair IsaacFICO Risk Score Classic 04FICO Risk Score Classic 98VantageScore 2.0VantageScore 3.0More than one credit scoring modelOther credit scoring modelNot applicableIf Code 8 is entered, specify in text the applicant’s orborrower’s other credit scoring model. Otherwise leave theFree Form Text field blank.Applicant or Borrower,Name & Version ofCredit Scoring ModelScoring model1.2.3.4.5.6.7.8.9.10.Equifax Beacon 5.0Experian Fair IsaacFICO Risk Score Classic 04FICO Risk Score Classic 98VantageScore 2.0VantageScore 3.0More than one credit scoring modelOther credit scoring modelNot applicableNo Co-ApplicantIf Code 8 is entered, specify in text the co-applicant’s or coborrower’s other credit scoring model. Otherwise leave theFree Form Text field blank.Reason(s) for Den

Sterling C O M P L I A N C E , L LC 2 P a g e Field # Data Field Name Data Point Name 63 Credit Score of Co-Applicant or Co- Borrower Credit Score 75 Origination Charges Origination Charges 76 Discount Points Discount Points 77 Lender Credits Lender Credits 78 Interest Rate Interest Rate 80 Debt-to-Income Ratio Debt-to-Income Ratio 81 Combined Loan-To-Value Ratio Combined Loan-To-Value Ratio