Both of these documents (Cx20787 and Cx20788) are provided in order to enable financial institutions to collect the disaggregated demographic information required for the Home Mortgage Disclosure Act (“HMDA”) reporting requirements outlined in 12 CFR § 1003.4, along with certain protected information required under the Equal Credit Opportunity Act (“ECOA”) requirements under Ibid. § 1002.13(a) (both as currently amended under 82 FR 45680 , 80 FR 66128 , and similar amendments). These particular forms are published by the Federal National Mortgage Association (“FNMA” or “Fannie Mae”) and the Federal Home Loan Mortgage Corporation (“FHLMC” or “Freddie Mac”) on their websites (see https://www.fanniemae.com/singlefamily/uniform-residential-loan-application and http://www.freddiemac.com/singlefamily/sell/ulad.html).
On September 26, 2017, both government-sponsored enterprises (“GSEs”) jointly announced updates to both the English- and Spanish-versions of the “Demographic Addendum” (see “URLA Implementation Timeline Update” at http://www.freddiemac.com/singlefamily/sell/ulad.html). As a result, we have updated Cx20787 and Cx20788 to match the latest editions of these forms.
We will also be modifying the forms to permit the free text fields for the “Other” racial/ethnic categories to print even if the “Other” checkbox is not selected. This is due to various instructions from the HMDA FIG instructions (available https://www.consumerfinance.gov/data-research/hmda/for-filers), including the following:
“If the applicant or borrower, or any co-applicant or co-borrower, did not select Code 14, but provided an other Hispanic or Latino ethnicity(ies) in the Ethnicity Free Form Text Field for Other Hispanic or Latino, your institution is permitted, but not required, to report Code 14 in one of the Ethnicity of Applicant or Borrower data fields. This will be counted as one of the five (5) reported ethnicities, whether or not you also choose to report Code 14 as one of the Ethnicity of Applicant or Borrower, or Ethnicity of Co-Applicant or Co-Borrower, data fields.” (p. 67, “For data collected in or after 2018”)
These changes will take effect on November 7, 2017. If you have any questions or concerns about these changes, please contact Client Support at 1.800.497.3584.