Before the loan advances, a licensing coordinator must resolve a HMDA reporting issue in a state-law refresher. What should happen?
Correct Answer
A) Treat covered dwelling-secured activity as HMDA data
Why this is correct: The Home Mortgage Disclosure Act (HMDA), implemented by Regulation C, requires covered financial institutions to collect, record, and report specific data for covered dwelling-secured loan applications and originations. The core requirement is to identify and treat qualifying activity as HMDA data. The correct action, "Treat covered dwelling-secured activity as HMDA data," directly aligns with this fundamental obligation. The licensing coordinator must ensure the issue is resolved by properly categorizing the loan activity for HMDA reporting before the loan advances. Why the other choices are wrong: "Use an internal exception instead of the required federal disclosure or timing rule" is wrong because internal policies cannot override binding federal HMDA requirements. "Wait until a regulator asks for the file before applying the federal requirement" is wrong because HMDA compliance is mandatory and proactive, not something triggered by a regulatory inquiry. "Rely on oral agreement when the rule requires documented compliance" is wrong because HMDA data collection and reporting require documented, verifiable records, not oral agreements. Exam tip: For HMDA questions, remember the core action: identify covered loans and collect the required data. Any option suggesting delay, oral agreements, or internal overrides is incorrect.
Why This Is the Correct Answer
The correct response is "Treat covered dwelling-secured activity as HMDA data" because Covered institutions collect and report HMDA data for covered mortgage applications and loans.
Why the Other Options Are Wrong
Option B: Use an internal exception instead of the required federal disclosure or timing rule.
Use an internal exception instead of the required federal disclosure or timing rule. is not correct because it does not apply the rule tested by this file scenario.
Option C: Wait until a regulator asks for the file before applying the federal requirement.
Wait until a regulator asks for the file before applying the federal requirement. is not correct because it does not apply the rule tested by this file scenario.
Option D: Rely on oral agreement when the rule requires documented compliance.
Rely on oral agreement when the rule requires documented compliance. is not correct because it does not apply the rule tested by this file scenario.
Memory Technique
HMDA reporting: identify the rule being tested, then choose the action that documents or applies that rule before the file moves forward.
Exam Tip
Match the file facts to HMDA reporting; do not choose an exception or shortcut that skips the required rule.
Common Mistakes to Avoid
- -Choosing an internal exception instead of the governing rule
- -Treating preliminary or informal facts as a substitute for required documentation
- -Answering from a familiar but unrelated mortgage topic
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