source:
  type: regulation
  id: hmda-12cfr-1003-supplement-i
  authority: "Supplement I to 12 CFR Part 1003 — Official Bureau Interpretations (Regulation C / HMDA Commentary)"
  description: "Supplement I to 12 CFR Part 1003 is the CFPB's official staff\ncommentary on Regulation C (HMDA). This register captures the most\noperationally-load-bearing commentary interpreting §§1003.2–.6\n(definitions, exempt transactions, LAR data fields, disclosure and\nreporting, and bona-fide-error enforcement). Each obligation cites\nthe verbatim comment text and identifies the parent rule it\ninterprets via the `interprets` field.\n"
obligations:
- id: hmda-12cfr-1003-supp-i-2b-prequalification-excluded
  canonical_id: hmda-12cfr-1003-supp-i-2b-prequalification-excluded
  section: "Supplement I — Comment 2(b)-2: Prequalification not reportable"
  description: "The Bureau interprets §1003.2(b) such that a prequalification request\n(a request for a preliminary determination on likely qualification,\nother than a preapproval request) is NOT an \"application\" for\nRegulation C reporting purposes. [LENDER] is not required to report\nprequalification requests on the LAR even if the same request would\nconstitute an \"application\" under Regulation B for adverse-action\npurposes.\n"
  interprets: hmda-12cfr-1003.2-b-application
  type: do
  audit_question: Does [LENDER]'s HMDA-reporting routing logic suppress prequalification requests from LAR inclusion (while still issuing any Reg B adverse-action notice that may be due), per Comment 2(b)-2?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: continuous
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - application-definition
  - prequalification
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 2(b)-2"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: 2. Prequalification. A prequalification request is a request by a prospective loan applicant (other than a request for preapproval) for a preliminary determination on whether the prospective loan applicant would likely qualify for credit under an institution's standards, or for a determination on the amount of credit for which the prospective applicant would likely qualify. Some institutions evaluate prequalification requests through a procedure that is separate from the institution's normal loan application process; others use the same process. In either case, Regulation C does not require an institution to report prequalification requests on the loan/application register, even though these requests may constitute applications under Regulation B for purposes of adverse action notices.
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the full Comment 2(b)-2.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Does the program account for the prequalification carve-out — HMDA routing suppresses prequalification requests from the LAR while still issuing any Reg B adverse-action notice that may be due on the same request?
  file_review: Spot-check prequalification requests; confirm none was reported on the LAR and any Reg B notice due was still issued.
  judgment: false
- id: hmda-12cfr-1003-supp-i-2b-preapproval-program-criteria
  canonical_id: hmda-12cfr-1003-supp-i-2b-preapproval-program-criteria
  section: "Supplement I — Comment 2(b)-3: Preapproval-program written-commitment criteria"
  description: "The Bureau interprets §1003.2(b)(2) such that a \"preapproval program\"\nrequires the written commitment to result from a comprehensive\ncreditworthiness review (income, resources, etc.) and may be\nconditioned only on property identification, no-material-change in\nthe applicant's financial condition, and ordinary closing\nconditions. A program described as \"preapproval\" but failing these\nelements is NOT a preapproval program under Reg C, regardless of\nlabel.\n"
  interprets: hmda-12cfr-1003.2-b-application
  type: do
  audit_question: Does [LENDER]'s preapproval program documentation evidence a comprehensive creditworthiness review and limit attached conditions to property-identification, no-material-change, and customary closing conditions, per Comment 2(b)-3?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: annual
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - preapproval-program
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 2(b)-3"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: "3. Requests for preapproval. To be a preapproval program as defined in § 1003.2(b)(2) , the written commitment issued under the program must result from a comprehensive review of the creditworthiness of the applicant, including such verification of income, resources, and other matters as is typically done by the institution as part of its normal credit evaluation program. In addition to conditions involving the identification of a suitable property and verification that no material change has occurred in the applicant's financial condition or creditworthiness, the written commitment may be subject only to other conditions (unrelated to the financial condition or creditworthiness of the applicant) that the lender ordinarily attaches to a traditional home mortgage application approval."
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the operative portion of Comment

      2(b)-3 defining preapproval-program criteria; remaining sentences

      (label-irrelevance and ad-hoc treatment) are paraphrased in

      description.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Does the program account for the preapproval-program definition — its preapproval documentation evidences a comprehensive creditworthiness review and limits attached conditions to property-identification, no-material-change, and customary closing conditions (so a mislabeled 'preapproval' isn't reported as one)?
  file_review: Spot-check the preapproval program against the three permitted condition categories and the comprehensive-review requirement.
  judgment: false
- id: hmda-12cfr-1003-supp-i-2d-extension-of-credit-new-debt
  canonical_id: hmda-12cfr-1003-supp-i-2d-extension-of-credit-new-debt
  section: "Supplement I — Comment 2(d)-2: Extension of credit means new debt obligation"
  description: "The Bureau interprets §1003.2(d) such that a dwelling-secured loan\nis a \"closed-end mortgage loan\" only if it involves an extension of\ncredit, which generally means the granting of credit pursuant to a\nnew debt obligation. Modifications, renewals, extensions, or\namendments of an existing debt obligation that do not satisfy and\nreplace it are NOT closed-end mortgage loans. Assumptions and New\nYork CEMA supplemental mortgages are the carve-outs.\n"
  interprets: hmda-12cfr-1003.2-d-closed-end-mortgage-loan
  type: do
  audit_question: For every dwelling-secured transaction, does [LENDER]'s HMDA-coverage decision distinguish new debt obligations from mere modifications/renewals/extensions of existing debt (which are not closed-end mortgage loans), with explicit handling for assumptions and NY CEMA transactions, per Comment 2(d)-2?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: continuous
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - closed-end-definition
  - extension-of-credit
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 2(d)-2"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: "2. Extension of credit. Under § 1003.2(d) , a dwelling-secured loan is not a closed-end mortgage loan unless it involves an extension of credit. For example, some transactions completed pursuant to installment sales contracts, such as some land contracts, depending on the facts and circumstances, may or may not involve extensions of credit rendering the transactions closed-end mortgage loans. In general, extension of credit under § 1003.2(d) refers to the granting of credit only pursuant to a new debt obligation. Thus, except as described in comments 2(d)-2.i and .ii, if a transaction modifies, renews, extends, or amends the terms of an existing debt obligation, but the existing debt obligation is not satisfied and replaced, the transaction is not a closed-end mortgage loan under § 1003.2(d) because there has been no new extension of credit."
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the operative portion of Comment

      2(d)-2; assumption and NY CEMA sub-items (i)-(ii) are paraphrased

      in description.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Does the program account for the new-debt-obligation test — its HMDA-coverage decision distinguishes new debt obligations from mere modifications/renewals/extensions that don't satisfy-and-replace, with explicit handling for assumptions and NY CEMA transactions?
  file_review: Spot-check modification/renewal/assumption/CEMA transactions; confirm the coverage decision applied the new-debt test rather than reporting them by default.
  judgment: false
- id: hmda-12cfr-1003-supp-i-2f-mixed-use-primary-use
  canonical_id: hmda-12cfr-1003-supp-i-2f-mixed-use-primary-use
  section: "Supplement I — Comment 2(f)-4: Mixed-use property — primary use governs"
  description: "The Bureau interprets §1003.2(f) such that a property used for both\nresidential and commercial purposes is a \"dwelling\" under HMDA if\nits primary use is residential. [LENDER] may use any reasonable\nstandard to determine primary use (e.g., square footage, income\ngenerated) and may select the standard case-by-case.\n"
  interprets: hmda-12cfr-1003.2-f-dwelling
  type: do
  audit_question: For every mixed-use property securing a [LENDER] loan/application, can [LENDER] document the reasonable primary-use standard applied (e.g., square footage, income) supporting the dwelling-vs-non-dwelling classification, per Comment 2(f)-4?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: underwriter
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - dwelling-definition
  - mixed-use
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 2(f)-4"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: 4. Mixed-use properties. A property used for both residential and commercial purposes, such as a building containing apartment units and retail space, is a dwelling if the property's primary use is residential. An institution may use any reasonable standard to determine the primary use of the property, such as by square footage or by the income generated. An institution may select the standard to apply on a case-by-case basis.
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the full Comment 2(f)-4.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Does the program account for mixed-use properties — capturing a documented reasonable primary-use standard (square footage, income) behind each dwelling-vs-non-dwelling classification?
  file_review: Spot-check mixed-use property files; confirm the documented primary-use basis for the dwelling classification. The compliance person judges whether the primary-use standard applied was reasonable.
  judgment: true
- id: hmda-12cfr-1003-supp-i-2g-asset-size-2026-threshold
  canonical_id: hmda-12cfr-1003-supp-i-2g-asset-size-2026-threshold
  section: "Supplement I — Comment 2(g)-2: 2026 asset-size exemption threshold ($59 million)"
  description: "The Bureau interprets §1003.2(g) by setting the 2026-data-collection\nasset-size exemption threshold at $59 million. Banks, savings\nassociations, and credit unions with assets at or below $59 million\nas of December 31, 2025, are exempt from collecting HMDA data for\n2026.\n"
  interprets: hmda-12cfr-1003.2-g-financial-institution-coverage
  type: do
  audit_question: Does [LENDER]'s annual HMDA-coverage determination check the 12/31/2025 asset balance against the $59 million 2026 threshold per Comment 2(g)-2 before committing to (or skipping) 2026 LAR collection?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: annual
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - financial-institution-coverage
  - asset-size-threshold
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 2(g)-2"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: 2. Adjustment of exemption threshold for banks, savings associations, and credit unions. For data collection in 2026, the asset-size exemption threshold is $59 million. Banks, savings associations, and credit unions with assets at or below $59 million as of December 31, 2025, are exempt from collecting data for 2026.
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the full Comment 2(g)-2.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Does the program account for the asset-size exemption — the annual HMDA-coverage determination checks the 12/31/2025 asset balance against the $59 million 2026 threshold before committing to or skipping 2026 LAR collection?
  file_review: Review the annual coverage determination; confirm the 12/31/2025 asset figure was compared against the $59M threshold and the collect/skip decision follows from it.
  judgment: false
- id: hmda-12cfr-1003-supp-i-3c3-temporary-financing
  canonical_id: hmda-12cfr-1003-supp-i-3c3-temporary-financing
  section: "Supplement I — Comment 3(c)(3)-1: Temporary financing exclusion requires designed-for-replacement"
  description: "The Bureau interprets §1003.3(c)(3) such that a loan or line of\ncredit is \"temporary financing\" — and excluded from HMDA reporting —\nonly if it is DESIGNED to be replaced by separate permanent\nfinancing extended to the same borrower at a later time. A\nshort-term loan that simply has a short maturity (e.g., a 9-month\ninvestor flip loan) is NOT temporary financing if it is not designed\nto be replaced by separate permanent financing.\n"
  interprets: hmda-12cfr-1003.2-e-covered-loan
  type: do
  audit_question: "For every short-term/bridge/construction loan [LENDER] excludes from HMDA reporting under §1003.3(c)(3), can [LENDER] document the design-for-replacement-by-separate-permanent-financing fact pattern (not merely the short term), per Comment 3(c)(3)-1?"
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: underwriter
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - excluded-transaction
  - temporary-financing
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 3(c)(3)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: "1. Temporary financing. Section 1003.3(c)(3) provides that closed-end mortgage loans or open-end lines of credit obtained for temporary financing are excluded transactions. A loan or line of credit is considered temporary financing and excluded under § 1003.3(c)(3) if the loan or line of credit is designed to be replaced by separate permanent financing extended by any financial institution to the same borrower at a later time."
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the headline of Comment 3(c)(3)-1;

      sub-examples (i)-(v) including the 9-month investor flip example

      are paraphrased in description.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Does the program account for the temporary-financing exclusion — short-term/bridge/construction loans are excluded only on a documented designed-to-be-replaced-by-separate-permanent-financing fact pattern, not merely a short maturity?
  file_review: Spot-check short-term loans excluded from HMDA; confirm the file documents design-for-replacement-by-separate-permanent-financing, not just a short term.
  judgment: false
- id: hmda-12cfr-1003-supp-i-4a-credit-decision-pre-closing
  canonical_id: hmda-12cfr-1003-supp-i-4a-credit-decision-pre-closing
  section: "Supplement I — Comment 4(a)-2.i: Only one institution reports an origination — the credit-decider"
  description: "The Bureau interprets §1003.4(a) such that when more than one\ninstitution is involved in originating a covered loan, only ONE\nreports the origination — and that institution is the one that made\nthe credit decision approving the application BEFORE closing or\naccount opening. Whose name the loan closed in is irrelevant. If the\ndecider sold the loan post-closing, the post-closing purchaser\nbecomes the reporter ONLY if the purchaser also approved before\nclosing.\n"
  interprets: hmda-12cfr-1003.4-a-data-collection
  type: do
  audit_question: For every broker-channel or correspondent-channel transaction [LENDER] is involved in, does the HMDA-reporting determination identify the institution that made the credit decision before closing as the LAR reporter (regardless of closing-name or post-close sale), per Comment 4(a)-2.i?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - credit-decision-attribution
  - multi-institution
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 4(a)-2.i"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: i. Only one financial institution reports each originated covered loan as an origination. If more than one institution was involved in the origination of a covered loan, the financial institution that made the credit decision approving the application before closing or account opening reports the loan as an origination. It is not relevant whether the loan closed or, in the case of an application, would have closed in the institution's name. If more than one institution approved an application prior to closing or account opening and one of those institutions purchased the loan after closing, the institution that purchased the loan after closing reports the loan as an origination.
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the principal paragraph of Comment

      4(a)-2.i defining the credit-decider as the LAR reporter.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Does the program account for multi-party originations — the HMDA-reporting determination names the institution that made the credit decision before closing as the LAR reporter (regardless of closing-name or post-close sale)?
  file_review: Spot-check broker-channel and correspondent-channel files; confirm the LAR reporter is the pre-closing credit-decider per the rule, not the closing-name institution.
  judgment: false
- id: hmda-12cfr-1003-supp-i-4a1i-uli-uniqueness
  canonical_id: hmda-12cfr-1003-supp-i-4a1i-uli-uniqueness
  section: "Supplement I — Comment 4(a)(1)(i)-1: ULI uniqueness"
  description: "The Bureau interprets §1003.4(a)(1)(i)(B)(2) such that each ULI must\nbe unique within [LENDER] and used only for the covered loan or\napplication to which it was first assigned. [LENDER] may not reuse\na ULI from a prior originated/reported loan for a new application,\nand refinancings must receive a different ULI from the loan being\nrefinanced. Multi-branch institutions must coordinate to prevent\ncross-branch ULI duplication.\n"
  interprets: hmda-12cfr-1003.4-a1-uli-assignment
  type: do
  audit_question: Does [LENDER]'s ULI-generation infrastructure enforce institution-wide (multi-branch) uniqueness and prevent reuse across calendar years or across original-vs-refinancing loans, per Comment 4(a)(1)(i)-1?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: continuous
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - uli
  - data-integrity
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 4(a)(1)(i)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: "1. ULI—uniqueness. Section 1003.4(a)(1)(i)(B) ( 2 ) requires a financial institution that assigns a universal loan identifier (ULI) to each covered loan or application (except as provided in § 1003.4(a)(1)(i)(D) and (E) ) to ensure that the character sequence it assigns is unique within the institution and used only for the covered loan or application. A financial institution should assign only one ULI to any particular covered loan or application, and each ULI should correspond to a single application and ensuing loan in the case that the application is approved and a loan is originated. A financial institution may use a ULI that was reported previously to refer only to the same loan or application for which the ULI was used previously or a loan that ensues from an application for which the ULI was used previously."
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the headline portion of Comment

      4(a)(1)(i)-1; the refinancing-different-ULI sentence and

      multi-branch sentence are paraphrased in description.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Do the P&Ps ensure the ULI-generation infrastructure enforces institution-wide (multi-branch) uniqueness and prevents reuse across calendar years and across original-vs-refinancing loans?
  file_review: Review the ULI-generation control and a sample of ULIs (including refinancings and multi-branch loans); confirm no duplication or cross-loan reuse.
  judgment: false
- id: hmda-12cfr-1003-supp-i-4a1i-uli-privacy
  canonical_id: hmda-12cfr-1003-supp-i-4a1i-uli-privacy
  section: "Supplement I — Comment 4(a)(1)(i)-2: ULI privacy — no direct PII"
  description: "The Bureau interprets §1003.4(a)(1)(i)(B)(3) to prohibit [LENDER]\nfrom embedding information that could directly identify the\napplicant or borrower in the ULI — including (without limitation)\nname, date of birth, SSN, driver's-license/identification number,\nalien-registration number, passport number, or employer/taxpayer\nidentification number.\n"
  interprets: hmda-12cfr-1003.4-a1-uli-assignment
  type: dont
  audit_question: Does [LENDER]'s ULI-generation algorithm exclude any borrower name, DOB, SSN, driver's-license/ID number, alien-registration number, passport number, and EIN/TIN, per Comment 4(a)(1)(i)-2?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: continuous
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - uli
  - pii-protection
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 4(a)(1)(i)-2"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: "2. ULI—privacy. Section 1003.4(a)(1)(i)(B) ( 3 ) prohibits a financial institution from including information that could be used to directly identify the applicant or borrower in the identifier that it assigns for the application or covered loan of the applicant or borrower. Information that could be used to directly identify the applicant or borrower includes, but is not limited to, the applicant's or borrower's name, date of birth, Social Security number, official government-issued driver's license or identification number, alien registration number, government passport number, or employer or taxpayer identification number."
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the full Comment 4(a)(1)(i)-2.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Do the P&Ps ensure the ULI-generation algorithm excludes any borrower name, DOB, SSN, driver's-license/ID number, alien-registration number, passport number, and EIN/TIN?
  file_review: Review the ULI-construction logic and a ULI sample; confirm no embedded direct identifiers.
  judgment: false
- id: hmda-12cfr-1003-supp-i-4a3-cashout-vs-refi
  canonical_id: hmda-12cfr-1003-supp-i-4a3-cashout-vs-refi
  section: "Supplement I — Comment 4(a)(3)-2: Cash-out refinancing classification driven by institution/investor guidelines"
  description: "The Bureau interprets §1003.4(a)(3) such that [LENDER] reports a\ncovered loan or application as a \"cash-out refinancing\" if it is a\nrefinancing under §1003.2(p) AND [LENDER] considered it a cash-out\nrefinancing in processing the application or setting terms (e.g.,\ninterest rate, origination charges) under its own or an investor's\nguidelines. The classification is driven by guideline-treatment,\nnot by an objective borrower-cash threshold.\n"
  interprets: hmda-12cfr-1003.4-a-data-collection
  type: do
  audit_question: For every refinancing [LENDER] reports as cash-out, can [LENDER] point to its own or an investor's guideline under which the transaction was processed/priced as a cash-out refinancing, per Comment 4(a)(3)-2?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: underwriter
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - loan-purpose
  - cashout-refi
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 4(a)(3)-2"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: "2. Purpose—refinancing and cash-out refinancing. Section 1003.4(a)(3) requires a financial institution to report whether a covered loan is, or an application is for, a refinancing or a cash-out refinancing. A financial institution reports a covered loan or an application as a cash-out refinancing if it is a refinancing as defined by § 1003.2(p) and the institution considered it to be a cash-out refinancing in processing the application or setting the terms (such as the interest rate or origination charges) under its guidelines or an investor's guidelines."
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the headline portion of Comment

      4(a)(3)-2; sub-examples (i)-(iii) illustrating different guideline

      regimes are paraphrased in description.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Does the program account for cash-out classification — every refinancing reported as cash-out ties back to [LENDER]'s or an investor's guideline under which it was processed/priced as cash-out (guideline-treatment, not an objective cash threshold)?
  file_review: Spot-check cash-out-reported refinancings; confirm the guideline under which the transaction was processed/priced as cash-out.
  judgment: false
- id: hmda-12cfr-1003-supp-i-4a8-action-taken-incomplete-vs-denied
  canonical_id: hmda-12cfr-1003-supp-i-4a8-action-taken-incomplete-vs-denied
  section: "Supplement I — Comment 4(a)(8)(i)-6: File closed for incompleteness vs. denial"
  description: "The Bureau interprets §1003.4(a)(8)(i) such that [LENDER] reports\n\"file closed for incompleteness\" when [LENDER] sent a Reg B\n1002.9(c)(2) notice of incompleteness and the applicant did not\nrespond in time before satisfying all underwriting conditions. If\n[LENDER] then provides a Reg B 1002.9(c)(1)(i) adverse-action\nnotice on the basis of incompleteness, [LENDER] may report the\naction as either \"file closed for incompleteness\" OR\n\"application denied\" — both are permissible.\n"
  interprets: hmda-12cfr-1003.4-a8-action-taken-and-date
  type: do
  audit_question: When [LENDER] sends a Reg B notice of incompleteness and the applicant fails to respond, does [LENDER]'s HMDA mapping consistently apply one of the two permitted action-taken values (file-closed-for-incompleteness or application-denied), per Comment 4(a)(8)(i)-6?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: continuous
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - action-taken
  - incompleteness
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 4(a)(8)(i)-6"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: "6. Action taken—file closed for incompleteness. A financial institution reports that the file was closed for incompleteness if the financial institution sent a written notice of incompleteness under Regulation B, 12 CFR 1002.9 (c)(2), and the applicant did not respond to the request for additional information within the period of time specified in the notice before the applicant satisfies all underwriting or creditworthiness conditions. See comment 4(a)(8)(i)-13. If a financial institution then provides a notification of adverse action on the basis of incompleteness under Regulation B, 12 CFR 1002.9 (c)(1)(i), the financial institution may report the action taken as either file closed for incompleteness or application denied. A preapproval request that is closed for incompleteness is not reportable under HMDA."
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the full Comment 4(a)(8)(i)-6.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Does the program account for the incompleteness-vs-denial mapping — when a Reg B notice of incompleteness was sent and the applicant didn't respond, HMDA consistently applies one of the two permitted action-taken values (file-closed-for-incompleteness or application-denied)?
  file_review: Spot-check files where a Reg B incompleteness notice was sent and went unanswered; confirm one of the two permitted action-taken codes was applied consistently.
  judgment: false
- id: hmda-12cfr-1003-supp-i-4a8-counteroffer-action-taken
  canonical_id: hmda-12cfr-1003-supp-i-4a8-counteroffer-action-taken
  section: "Supplement I — Comment 4(a)(8)(i)-9: Counteroffers — action-taken mapping"
  description: "The Bureau interprets §1003.4(a)(8)(i) such that if [LENDER] makes\na counteroffer (e.g., shorter maturity, different rate, different\namount) and the applicant declines or fails to respond, [LENDER]\nreports the action as a DENIAL on the original terms requested. If\nthe applicant agrees to proceed with the counteroffer, [LENDER]\nreports the disposition based on the counteroffer terms.\n"
  interprets: hmda-12cfr-1003.4-a8-action-taken-and-date
  type: do
  audit_question: For every counteroffer [LENDER] makes, does [LENDER]'s HMDA mapping report "denied on original terms" when the applicant declines/fails to respond, and report the counteroffer disposition only when the applicant agrees to proceed, per Comment 4(a)(8)(i)-9?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: continuous
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - action-taken
  - counteroffer
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 4(a)(8)(i)-9"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: "9. Action taken—counteroffers. If a financial institution makes a counteroffer to lend on terms different from the applicant's initial request (for example, for a shorter loan maturity, with a different interest rate, or in a different amount) and the applicant declines to proceed with the counteroffer or fails to respond, the institution reports the action taken as a denial on the original terms requested by the applicant. If the applicant agrees to proceed with consideration of the financial institution's counteroffer, the financial institution reports the action taken as the disposition of the application based on the terms of the counteroffer."
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the operative portion of Comment

      4(a)(8)(i)-9; the subsequent conditional-approval examples are

      omitted as derivative of the principal rule.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Does the program account for counteroffer mapping — HMDA reports 'denied on original terms' when the applicant declines/fails to respond to a counteroffer, and reports the counteroffer disposition only when the applicant agrees to proceed?
  file_review: Spot-check counteroffer files; confirm the action-taken code follows the accept/decline outcome per the rule.
  judgment: false
- id: hmda-12cfr-1003-supp-i-4a9-property-address-securing-property
  canonical_id: hmda-12cfr-1003-supp-i-4a9-property-address-securing-property
  section: "Supplement I — Comment 4(a)(9)(i)-1: Property address is the SECURING-property address, not the mailing address"
  description: "The Bureau interprets §1003.4(a)(9)(i) such that [LENDER] reports\nthe property address of the location of the property SECURING the\ncovered loan (or proposed to secure it). The address must correspond\nto the property identified in the legal obligation — not to the\napplicant's mailing address or post-office box.\n"
  interprets: hmda-12cfr-1003.4-a9-property-location
  type: do
  audit_question: Does [LENDER]'s LAR-population process pull the property address from the secured/subject-property field rather than from the borrower-mailing-address field, per Comment 4(a)(9)(i)-1?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - property-address
  - data-integrity
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 4(a)(9)(i)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: "1. General. Except for partially exempt transactions under § 1003.3(d) , § 1003.4(a)(9)(i) requires a financial institution to report the property address of the location of the property securing a covered loan or, in the case of an application, proposed to secure a covered loan. The address should correspond to the property identified on the legal obligation related to the covered loan. For applications that did not result in an origination, the address should correspond to the location of the property proposed to secure the loan as identified by the applicant. For example, assume a loan is secured by a property located at 123 Main Street, and the applicant's or borrower's mailing address is a post office box. The financial institution should not report the post office box, and should report 123 Main Street."
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the full Comment 4(a)(9)(i)-1.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Do the P&Ps ensure the LAR-population process pulls the property address from the secured/subject-property field (the legal-obligation property), never the borrower mailing address or PO box?
  file_review: Spot-check LAR records against the subject-property field; confirm the reported address is the securing property, not a mailing address.
  judgment: false
- id: hmda-12cfr-1003-supp-i-4a10iii-income-relied-on
  canonical_id: hmda-12cfr-1003-supp-i-4a10iii-income-relied-on
  section: "Supplement I — Comment 4(a)(10)(iii)-1: Income — only the income relied on"
  description: "The Bureau interprets §1003.4(a)(10)(iii) such that when [LENDER]\nevaluates income as part of a credit decision, [LENDER] reports only\nthe gross annual income RELIED ON in making that decision. Income\nnot relied on (e.g., commission income excluded because earned <12\nmonths) is not reported. Cosigner income is included to the extent\nrelied upon; guarantor income (secondary liability only) is not.\n"
  interprets: hmda-12cfr-1003.4-a10-applicant-demographics-age-income
  type: do
  audit_question: For every LAR record, does [LENDER]'s income field reflect only the income components actually relied on in the credit decision (excluding income that policy-screened out, including cosigner income to extent relied on, excluding guarantor income), per Comment 4(a)(10)(iii)-1?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: underwriter
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - income-reporting
  - data-integrity
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 4(a)(10)(iii)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: "1. Income data—income relied on. When a financial institution evaluates income as part of a credit decision, it reports the gross annual income relied on in making the credit decision. For example, if an institution relies on an applicant's salary to compute a debt-to-income ratio but also relies on the applicant's annual bonus to evaluate creditworthiness, the institution reports the salary and the bonus to the extent relied upon. If an institution relies on only a portion of an applicant's income in its determination, it does not report that portion of income not relied on. For example, if an institution, pursuant to lender and investor guidelines, does not rely on an applicant's commission income because it has been earned for less than 12 months, the institution does not include the applicant's commission income in the income reported."
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the operative portion of Comment

      4(a)(10)(iii)-1; the cosigner-vs-guarantor sentence and verified-

      gross-income sentence are paraphrased in description.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Does the program account for the income-relied-on rule — the LAR income field reflects only the income actually relied on in the credit decision (excluding policy-screened-out income, including cosigner income to the extent relied on, excluding guarantor income)?
  file_review: Spot-check LAR income against the underlying income worksheet and credit decision; the compliance person judges whether the reported figure matches the income actually relied on (HMDA data accuracy).
  judgment: true
- id: hmda-12cfr-1003-supp-i-4a16-denial-reasons-specific
  canonical_id: hmda-12cfr-1003-supp-i-4a16-denial-reasons-specific
  section: "Supplement I — Comment 4(a)(16)-1: Denial reasons must be specific and accurate"
  description: "The Bureau interprets §1003.4(a)(16) such that [LENDER] reports the\nprincipal reason or reasons it denied the application, indicating\nup to four reasons. [LENDER] reports only the principal reasons even\nif there are fewer than four. The reported reasons must be SPECIFIC\nand accurately describe the principal reason(s) for denial — generic\nplaceholders or padding to reach four reasons is impermissible.\n"
  interprets: hmda-12cfr-1003.4-a16-denial-reasons
  type: do
  audit_question: For every denied application reported on the LAR, does [LENDER] populate up to four SPECIFIC principal denial reasons that accurately describe the credit-decision basis (no generic placeholders, no padding to reach four), per Comment 4(a)(16)-1?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: underwriter
  cadence: per-denial
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - denial-reasons
  - data-integrity
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 4(a)(16)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: "1. Reason for denial—general. A financial institution complies with § 1003.4(a)(16) by reporting the principal reason or reasons it denied the application, indicating up to four reasons. The financial institution should report only the principal reason or reasons it denied the application, even if there are fewer than four reasons. For example, if a financial institution denies the application because of the applicant's credit history and debt-to-income ratio, the financial institution need only report these two principal reasons. The reasons reported must be specific and accurately describe the principal reason or reasons the financial institution denied the application."
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the full Comment 4(a)(16)-1.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Does the program account for denial-reason quality — denied LAR records carry up to four SPECIFIC principal reasons that accurately describe the credit-decision basis, with no generic placeholders and no padding to reach four?
  file_review: Spot-check denied LAR records against the credit-decision file; the compliance person judges whether the reported reasons are specific and accurately describe the principal basis for denial (HMDA data accuracy).
  judgment: true
- id: hmda-12cfr-1003-supp-i-4a23-dti-one-of-multiple
  canonical_id: hmda-12cfr-1003-supp-i-4a23-dti-one-of-multiple
  section: "Supplement I — Comment 4(a)(23)-2: DTI was a factor — must be reported even if not dispositive"
  description: "The Bureau interprets §1003.4(a)(23) such that [LENDER] \"relies on\"\nthe DTI ratio in the credit decision if DTI was a factor — even if\nnot the dispositive factor. If DTI was one of multiple factors,\n[LENDER] must report it on the LAR, even if the application was\ndenied for an unrelated underwriting requirement.\n"
  interprets: hmda-12cfr-1003.4-a23-dti
  type: do
  audit_question: For every credit-decisioned application in which DTI was considered, does [LENDER]'s LAR populate the DTI ratio (rather than reporting "not applicable") even when denial cited a non-DTI reason, per Comment 4(a)(23)-2?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: underwriter
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - dti-reporting
  - data-integrity
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 4(a)(23)-2"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: "2. Transactions for which a debt-to-income ratio was one of multiple factors. A financial institution relies on the ratio of the applicant's or borrower's total monthly debt to total monthly income (debt-to-income ratio) in making the credit decision if the debt-to-income ratio was a factor in the credit decision even if it was not a dispositive factor. For example, if the debt-to-income ratio was one of multiple factors in a financial institution's credit decision, the financial institution has relied on the debt-to-income ratio and complies with § 1003.4(a)(23) by reporting the debt-to-income ratio, even if the financial institution denied the application because one or more underwriting requirements other than the debt-to-income ratio were not satisfied."
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the full Comment 4(a)(23)-2.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Does the program account for the 'DTI as one of multiple factors' rule — the LAR populates the DTI ratio whenever DTI was a factor in the credit decision, even where denial cited a non-DTI reason (rather than reporting 'not applicable')?
  file_review: Spot-check credit-decisioned files where DTI was considered; confirm the DTI ratio was reported even when denial cited another reason.
  judgment: false
- id: hmda-12cfr-1003-supp-i-4a28-property-value-relied-on
  canonical_id: hmda-12cfr-1003-supp-i-4a28-property-value-relied-on
  section: "Supplement I — Comment 4(a)(28)-1: Property value — report the value relied on"
  description: "The Bureau interprets §1003.4(a)(28) such that [LENDER] reports the\nproperty value RELIED ON in making the credit decision — whether\nthat is an appraisal, an automated valuation model report, a broker\nprice opinion, or the purchase price used in calculating LTV. The\nrule does not prescribe a particular valuation method.\n"
  interprets: hmda-12cfr-1003.4-a24-cltv
  type: do
  audit_question: For every LAR record, does [LENDER]'s property-value field reflect the specific valuation actually relied on in the credit decision (appraisal, AVM, BPO, or purchase price as applicable), per Comment 4(a)(28)-1?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: underwriter
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - property-value
  - data-integrity
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 4(a)(28)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: "1. General. Except for partially exempt transactions under § 1003.3(d) , § 1003.4(a)(28) requires a financial institution to report the property value relied on in making the credit decision. For example, if the institution relies on an appraisal or other valuation for the property in calculating the loan-to-value ratio, it reports that value; if the institution relies on the purchase price of the property in calculating the loan-to-value ratio, it reports that value."
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the full Comment 4(a)(28)-1.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Does the program account for the property-value-relied-on rule — the LAR property-value field reflects the specific valuation actually relied on in the credit decision (appraisal, AVM, BPO, or purchase price)?
  file_review: Spot-check LAR property values against the valuation the credit decision relied on; the compliance person judges whether the reported value matches the one relied on (HMDA data accuracy).
  judgment: true
- id: hmda-12cfr-1003-supp-i-4a34-mlo-primary-responsibility
  canonical_id: hmda-12cfr-1003-supp-i-4a34-mlo-primary-responsibility
  section: "Supplement I — Comment 4(a)(34)-3: Multiple MLOs — report the primary-responsibility MLO"
  description: "The Bureau interprets §1003.4(a)(34) such that when more than one\nindividual associated with a covered loan or application meets the\ndefinition of a mortgage loan originator, [LENDER] reports the\nNMLSR ID of the MLO with PRIMARY responsibility for the transaction\nas of the date of action taken. A reasonable WRITTEN policy\ndetermining primary responsibility is required for compliance.\n"
  interprets: hmda-12cfr-1003.4-a34-mlo-nmls
  type: do
  audit_question: Does [LENDER] maintain a reasonable WRITTEN policy assigning primary responsibility among multiple MLOs on a single transaction, and does the LAR-population process select the primary-responsibility MLO's NMLSR ID per that policy as of the action-taken date, per Comment 4(a)(34)-3?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-application
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - mlo-nmls
  - primary-responsibility
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 4(a)(34)-3"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: "3. Multiple mortgage loan originators. If more than one individual associated with a covered loan or application meets the definition of a mortgage loan originator, as defined in Regulation G, 12 CFR 1007.102 , or Regulation H, 12 CFR 1008.23 , a financial institution complies with § 1003.4(a)(34) by reporting the NMLSR ID of the individual mortgage loan originator with primary responsibility for the transaction as of the date of action taken pursuant to § 1003.4(a)(8)(ii). A financial institution that establishes and follows a reasonable, written policy for determining which individual mortgage loan originator has primary responsibility for the reported transaction as of the date of action taken complies with § 1003.4(a)(34)."
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the full Comment 4(a)(34)-3.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Does the program account for multiple-MLO transactions — a reasonable WRITTEN policy assigns primary responsibility, and the LAR reports that MLO's NMLSR ID as of the action-taken date?
  file_review: Confirm the written primary-responsibility policy exists; spot-check multi-MLO files to confirm the reported NMLSR ID is the primary-responsibility MLO per the policy.
  judgment: false
- id: hmda-12cfr-1003-supp-i-4f-quarterly-recording-30-day
  canonical_id: hmda-12cfr-1003-supp-i-4f-quarterly-recording-30-day
  section: "Supplement I — Comment 4(f)-1: Quarterly LAR recording within 30 days of quarter-end"
  description: "The Bureau interprets §1003.4(f) such that [LENDER] must record the\nHMDA-reportable data on a loan/application register within 30\ncalendar days after the end of the calendar quarter in which final\naction is taken. [LENDER] may record on a single LAR or maintain\nseparate LARs by branch or by loan type.\n"
  interprets: hmda-12cfr-1003.4-f-quarterly-recording
  type: do
  audit_question: Does [LENDER]'s LAR-recording infrastructure complete data recording within 30 calendar days after each quarter's end for all final actions in that quarter, per Comment 4(f)-1?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: quarterly
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - quarterly-recording
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 4(f)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: "1. General. Section 1003.4(f) requires a financial institution to record the data collected pursuant to § 1003.4 on a loan/application register within 30 calendar days after the end of the calendar quarter in which final action is taken. Section 1003.4(f) does not require a financial institution to record data on a single loan/application register on a quarterly basis. Rather, for purposes of § 1003.4(f) , a financial institution may record data on a single loan/application register or separately for different branches or different loan types (such as home purchase or home improvement loans, or loans on multifamily dwellings)."
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the full Comment 4(f)-1.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Do the P&Ps ensure HMDA-reportable data for each quarter's final actions is recorded on a LAR within 30 calendar days after quarter-end (single or split LARs permitted)?
  file_review: Review the recording-event evidence for each quarter; confirm recording completed within 30 days of quarter-end.
  judgment: false
- id: hmda-12cfr-1003-supp-i-5a1ii-quarterly-reporting-60000
  canonical_id: hmda-12cfr-1003-supp-i-5a1ii-quarterly-reporting-60000
  section: "Supplement I — Comment 5(a)-1.i: Quarterly reporting trigger — 60,000 loans/applications"
  description: "The Bureau interprets §1003.5(a)(1)(ii) such that within 60 calendar\ndays after each calendar quarter (except the fourth quarter),\n[LENDER] must submit its quarterly LAR if it reported, for the\npreceding calendar year, at least 60,000 covered loans and\napplications combined (excluding purchased covered loans).\n"
  interprets: hmda-12cfr-1003.5-a1-ii-quarterly-submission
  type: do
  audit_question: Does [LENDER]'s annual HMDA-volume review check whether the prior-year combined loan/application volume (excluding purchased loans) reached 60,000, and if so, schedule quarterly submissions within 60 days of each Q1/Q2/Q3 quarter-end, per Comment 5(a)-1.i?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: quarterly
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - quarterly-reporting
  - volume-trigger
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 5(a)-1.i"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: "i. Section 1003.5(a)(1)(ii) requires that, within 60 calendar days after the end of each calendar quarter except the fourth quarter, a financial institution that reported for the preceding calendar year at least 60,000 covered loans and applications, combined, excluding purchased covered loans, must submit its loan/application register containing all data required to be recorded for that quarter pursuant to § 1003.4(f) ."
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the headline of Comment 5(a)-1.i;

      the worked example is omitted as derivative of the principal rule.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Does the program account for the 60,000-volume quarterly trigger — the annual volume review checks whether prior-year combined loans/applications (excluding purchased) hit 60,000 and, if so, schedules Q1/Q2/Q3 submissions within 60 days of each quarter-end?
  file_review: Review the annual volume determination; confirm the 60,000 threshold check and, if met, that quarterly submissions were scheduled.
  judgment: false
- id: hmda-12cfr-1003-supp-i-6b2-geocoding-tool-safe-harbor
  canonical_id: hmda-12cfr-1003-supp-i-6b2-geocoding-tool-safe-harbor
  section: "Supplement I — Comment 6(b)-2: Census-tract geocoding-tool safe harbor (and its limits)"
  description: "The Bureau interprets §1003.6(b)(2) such that obtaining census tract\nnumbers from the geocoding tool on the Bureau's website is an\nexample of a procedure reasonably adapted to avoid errors, and a\ncensus-tract error is not a violation if [LENDER] obtained the\nnumber from that tool. The safe harbor does NOT cover (i) failure\nto provide the census tract because the tool returned no result, or\n(ii) errors caused by entering an inaccurate property address.\n"
  interprets: hmda-12cfr-1003.6-b2-census-tract-error
  type: do
  audit_question: Does [LENDER]'s LAR-population process use the Bureau's geocoding tool with the actual property address (not a mailing address) for census tract, and does [LENDER] have a non-safe-harbor fallback when the tool returns no result, per Comment 6(b)-2?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: continuous
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - hmda
  - supplement-i
  - commentary
  - bona-fide-error
  - geocoding-tool
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1003 — Comment 6(b)-2"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1003
    snapshot_id: e27f675705358aff
    fetched_at: '2026-05-22T11:32:41Z'
    content_hash: sha256:8ea946d7f8b23b072ddc1b33e24430070d8fd5302c8c6bf5d8a894cd9bfe4214
    paragraph_quote: "2. Information from the Bureau. Section 1003.6(b)(2) provides that an incorrect entry for census tract number is deemed a bona fide error, and is not a violation of the Act or this part, provided that the financial institution maintains procedures reasonably adapted to avoid an error. Obtaining the census tract numbers for covered loans and applications from a geocoding tool available on the Bureau's Web site that identifies the census tract of a property using property addresses entered by users is an example of a procedure reasonably adapted to avoid errors under § 1003.6(b)(2) . Accordingly, a census tract error is not a violation of the Act or this part if the financial institution obtained the census tract number from the geocoding tool on the Bureau's Web site. However, a financial institution's failure to provide the correct census tract number for a covered loan or application on its loan/application register, as required by § 1003.4(a)(9)(ii)(C) or (e), because the geocoding tool on the Bureau's Web site did not provide a census tract number for the property address entered by the financial institution is not excused as a bona fide error. In addition, a census tract error caused by a financial institution entering an inaccurate property address into the geocoding tool on the Bureau's Web site is not excused as a bona fide error."
    drafter_attestation: 'Copied verbatim from snapshot e27f675705358aff (content.txt) at

      2026-05-22T13:00Z. Substring is the full Comment 6(b)-2.

      '
  promoted_at: '2026-05-22T12:17:10+00:00'
  promoted_from: hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  program_review: Does the program account for the geocoding safe harbor and its limits — the LAR-population process uses the Bureau's geocoding tool with the ACTUAL property address (not a mailing address) and has a non-safe-harbor fallback when the tool returns no result?
  file_review: Spot-check census-tract population; confirm the actual property address was used and a fallback exists for no-result cases (entering a wrong address or a no-result tool response is not excused).
  judgment: false
_promotion_history:
- promoted_at: '2026-05-22T12:17:10+00:00'
  candidate_path: obligations\_remediation\_round_b_drafts\hmda-12cfr-1003-supplement-i-roundb-v1.yaml
  candidates_promoted: 21
  candidates_skipped_existing: 0
