Does the final TRID rule definition of application trigger HMDA reporting?

Short answer is no. The Bureau received a lot of comment from the industry requesting that the Bureau create one common definition of application that would apply across HMDA, ECOA, TILA, and RESPA. The Bureau ultimately decided that, while it created a uniform definition of application for TILA and RESPA (which existed beforehand), HMDA and ECOA serve different purposes so the definitions of application under HMDA and ECOA remain unchanged under this rule.

Notably, when the Bureau proposed its amendments to HMDA, it disclaimed any intent to bring that definition of application in line with TILA-RESPA, but instead stated that the HMDA definition would continue serving its own separate purpose.

Note: This transcript has been edited from the February 2015 TRID webinar for clarity and completeness.

Answered By: Ben Olson

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