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Run: HMDA Reportability Determination Checklist

Use this HMDA Reportability Determination Checklist to decide whether a mortgage transaction is reportable under Regulation C and document the basis for incl...

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Transaction Intake and Context

Transaction type and application stage identified critical (required)

Confirm whether the file is an application, origination, purchase, refinance, home improvement, or other transaction type relevant to HMDA analysis.

Note (optional)

Action date documented critical (required)

Capture the application date, action taken date, or closing date used for HMDA determination.

Property location and occupancy information available critical (required)

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.

Yes No N/A

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 critical (required)

Confirm the institution meets HMDA coverage criteria for the relevant reporting year.

Yes No N/A

Closed-end mortgage loan volume threshold met

Document the number of closed-end mortgage loans originated in the prior two calendar years.

Note (optional)

Open-end line of credit volume threshold met

Document the number of open-end lines of credit originated in the prior two calendar years.

Note (optional)

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 critical (required)

Determine whether the transaction is secured by a dwelling as defined for HMDA purposes.

Yes No N/A

Transaction purpose is covered critical (required)

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.

Yes No N/A

Borderline or ambiguous coverage escalated

Confirm that any uncertain coverage determination was escalated for compliance review before final disposition.

Yes No N/A

Final HMDA Determination and Filing Readiness

Final determination recorded critical (required)

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.

Yes No N/A

Corrective action or follow-up owner assigned

Enter the person or team responsible for resolving missing data, exceptions, or escalation items.

Inspector signature critical (required)

Compliance reviewer attests that the HMDA reportability determination is complete and supported by the file record.

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