Using TRID application definition for HMDA

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Question:

My financial institution has decided to use the 6 items that mandate TRID disclosures to trigger an application for HMDA. Is this an acceptable definition:

Answer:

While HMDA allows each financial institution to define what is a HMDA application, using the TRID definition can lead to problems when the application is denied quickly or withdrawn or closed for incompleteness prior to receiving sufficient data to complete the HMDA LAR. Some fields such as property address and geocoding allow a response such as not applicable when final action occurs prior to receipt of the information, while other fields like age must be completed for every application involving a natural person. Defining applications for HMDA should take reporting rules into consideration. Full HMDA reporters have more fields to consider than those that are partially exempt.

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