A customer-service escalation raises an HMDA Reporting Requirements question for a training manager. What answer should guide the file?
Correct Answer
D) Record the action taken and reportable data points
Why this is correct: The Home Mortgage Disclosure Act (HMDA) requires covered institutions to collect and report specific data points for covered mortgage applications and loans. The core compliance duty is to accurately record the action taken on the application (e.g., originated, denied, withdrawn) and all reportable data (e.g., loan amount, property location, applicant demographics) as required by Regulation C. This creates the data set for annual reporting to the regulator. Why the other choices are wrong: "Use an internal exception instead of the required federal disclosure or timing rule" is wrong because HMDA has no provision for internal exceptions; it is a mandatory data collection and reporting statute. "Wait until a regulator asks for the file before applying the federal requirement" is wrong because HMDA requires proactive annual reporting, not reactive compliance upon request. "Rely on oral agreement when the rule requires documented compliance" is wrong because HMDA data must be recorded in writing and verified for accuracy; oral agreements do not satisfy this documentation requirement. Exam tip: For HMDA, think "collect and report." The rule is about systematic data recording, not discretionary disclosure timing.
Why This Is the Correct Answer
The correct response is "Record the action taken and reportable data points" because Covered institutions collect and report HMDA data for covered mortgage applications and loans.
Why the Other Options Are Wrong
Option A: 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 B: 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 C: 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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