The Consumer Financial Protection Bureau (“CFPB”) published two additional Home Mortgage Disclosure Act (“HMDA”) FAQs this week. The new FAQs relate to multiple data points and reporting requirements when information is not the dispositive factor in the decision. The new FAQs fall under the heading “Multiple data points” and ask: 1) Whether a financial institution is required to report the credit score, DTI, and CLTV relied on in making a credit decision when those factors were not the dispositive factors in the decision and 2) When income and property value are factors, but not dispositive factors, in a credit decision, whether those data points should be reported.
