Getting HMDA information on business loans

Answered by:

Question:

Should a written application be required for all business purpose applications, including those for HMDA reportable transactions?

Answer:

A written application can be required but it will not necessarily provide all information needed for the HMDA LAR. It also may not be appropriate for larger commercial accounts, especially for long time customers. Consider an interview checklist for loan officers to be completed in the application conversation that covers items such as a “best guess” of the number of units in a multifamily residential property to be purchased. Considering the HMDA LAR in the initial discussion can allow for proper reporting if the application is later withdrawn before final data is received.

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