When HMDA 2018 Rule Applies is selected, how do the reasons selected in Document Data for the Notice of Action Taken affect the Reasons for Denial in the Origination/Disposition area on the Calculations page?
Based on Appendix A to Part 1003—Form and Instructions for Completion of HMDA
Loan/Application Register, the Reason Type found within the Action Reason
section in Document Data will default from the Notice of Action Taken to the
Reasons for Denial as follows:
| Reason Type from Notice of Action Taken | Reasons for Denial in Origination/Disposition |
|---|---|
| Unable to verify credit references | 6 = Unverifiable information |
| Income insufficient for amount of credit requested | 1 = Debt-to-income ratio |
| Excessive obligations in relation to income | 1 = Debt-to-income ratio |
| Unable to verify income | 6 = Unverifiable information |
| Temporary or irregular employment | 2 = Employment history |
| Unable to verify employment | 6 = Unverifiable information |
| Length of employment | 2 = Employment history |
| Length of residence | 9 = Other; ‘Length of residence’ will be included as the Reasons for Denial Description |
| Temporary residence | 9 = Other; ‘Temporary residence’ will be included as the Reasons for Denial Description |
| Unable to verify residence | 6 = Unverifiable information |
| No credit file | 3 = Credit history |
| Limited credit experience | 3 = Credit history |
| Lack of collateral | 4 = Collateral |
| Delinquent past or present credit obligations | 3 = Credit history |
| Collection action or judgment | 3 = Credit history |
| Bankruptcy | 3 = Credit history |
| Incomplete application | 7 = Credit application incomplete |
| Poor credit performance | 3 = Credit history |
| Too few credit references | 3 = Credit history |
| Credit references unacceptable | 3 = Credit history |
| Garnishment or attachment | 3 = Credit history |
| Foreclosure or repossession | 3 = Credit history |
| Number of recent inquiries on credit bureau report | 3 = Credit history |
| No credit score | 3 = Credit history |
| Other | 9 = Other; what you have entered in Other Reason Description will be included as the Reasons for Denial Description |
You are able to change the defaulted reasons by selecting Override Reason for Denial. Note that if you select Override Reason for Denial and later make edits to the Reason Type on the Notice of Action Taken document, the Reasons for Denial that you have manually selected in the Origination/Disposition area will be retained. If you want to revert to the defaulted reasons, unselect Override Reason for Denial. Reasons for Denial do not default to or change the values disclosed on the Notice of Action Taken document.