HMDA Reportability Determination Checklist

Decision checklist for determining whether a transaction is reportable under HMDA Regulation C, including coverage, institution threshold, transaction type, and final reporting determination.

Transaction Identification

• Loan/application identifier recorded
• Application date or origination date recorded
• Applicant property type identified
• Transaction file contains sufficient documentation to evaluate HMDA status

Institution Coverage Threshold

• Closed-end mortgage originations threshold met for applicable reporting year
• Open-end line of credit originations threshold met for applicable reporting year
• Applicable threshold documented for the institution
• Threshold determination supported by recent origination data

Covered Loan or Application Screening

• Transaction is a loan or application for dwelling-secured credit
• Transaction is excluded from HMDA coverage based on Regulation C exclusions
• Transaction is a covered closed-end mortgage loan or open-end line of credit
• Action taken is reportable under HMDA

Reportability Decision and Rationale

• Final HMDA reportability determination completed
• Rationale cites the specific coverage rule or exclusion applied
• Any exception, ambiguity, or escalation documented
• Compliance review or second-level approval obtained when needed