HMDA Reportability Determination Checklist

Decision checklist for determining whether a transaction is reportable under HMDA Regulation C coverage rules and documenting the basis for inclusion or exclusion.

Transaction Intake and Context

• Transaction type and application stage identified
  Confirm whether the file is an application, origination, purchase, refinance, home improvement, or other transaction type relevant to HMDA analysis.
• Action date documented
  Capture the application date, action taken date, or closing date used for HMDA determination.
• Property location and occupancy information available
  Confirm the file contains sufficient information to evaluate whether the dwelling is located in a HMDA-reportable geography and whether the purpose is dwelling-related.
• Supporting source documents reviewed
  Identify the documents used to determine HMDA reportability.
• Reviewer notes and rationale captured
  Summarize the key facts supporting the HMDA determination, including any ambiguity or exception handling.

Institution Coverage Test

• Institution is a covered financial institution under Regulation C
  Confirm the institution meets HMDA coverage criteria for the relevant reporting year.
• Closed-end mortgage loan volume threshold met
  Document the number of closed-end mortgage loans originated in the prior two calendar years.
• Open-end line of credit volume threshold met
  Document the number of open-end lines of credit originated in the prior two calendar years.
• Coverage determination source verified
  Identify the source used to confirm institutional coverage and volume thresholds.

Transaction Coverage Under Regulation C

• Transaction is secured by a dwelling
  Determine whether the transaction is secured by a dwelling as defined for HMDA purposes.
• Transaction purpose is covered
  Identify whether the purpose is home purchase, home improvement, refinance, cash-out refinance, or another covered purpose.
• Dwelling-related property type confirmed
  Confirm the collateral or property type for HMDA analysis.
• Loan purpose exception or exclusion reviewed
  Check whether any HMDA exclusion applies, such as a transaction that is not reportable despite being mortgage-related.
• Borderline or ambiguous coverage escalated
  Confirm that any uncertain coverage determination was escalated for compliance review before final disposition.

Final HMDA Determination and Filing Readiness

• Final determination recorded
  Document the final HMDA reportability outcome.
• Reason for non-reportability documented
  If the transaction is not reportable, explain the basis for exclusion with enough detail for audit trail and QC review.
• HMDA filing deadline impact considered
  Confirm whether the determination affects current-cycle HMDA reporting readiness and whether the file must be resolved before filing.
• Corrective action or follow-up owner assigned
  Enter the person or team responsible for resolving missing data, exceptions, or escalation items.
• Inspector signature
  Compliance reviewer attests that the HMDA reportability determination is complete and supported by the file record.