Last week, the CFPB released two HMDA FAQs.

1. Are financial institutions required to report the credit score, DTI, and CLTV relied on in
making a credit decision when such data is not the dispositive factor?

Yes. Credit underwriting data such as credit score, debt-to-income ratio (DTI), and
combined loan-to-value ratio (CLTV) must be reported if they were a factor relied on in
making a credit decision—even if the data was not the dispositive factor. For purposes
of Regulation C, it does not matter whether the application is approved or denied; if
certain data was relied on in making a credit decision, such data must be reported.

2. When income and property value are factors in the credit decision, though not the
dispositive factor, should such data points be reported?

Yes. When a credit decision is made, sections 1003.4(a)(10)(iii) and 1003.4(a)(28)
require reporting of the data “relied on in making the credit decision.” Hence, if these
data are relied on in making a credit decision, such data must be reported. There is no
requirement in Regulation C for either of these data points to be the dispositive factor in
order to be reported.

You can access the FAQs here: https://www.consumerfinance.gov/policy
compliance/guidance/mortgage-resources/hmda-reporting-requirements/home-mortgage-disclosure
act-faqs/