HMDA and Property Value
Issue/Inquiry
When the HMDA data integrity was audited, the Bank discovered that the appraised value of the property for purchase-money mortgage loans did not agree with the value in the appraisal field. When this was discussed with the Lending area, they indicated that they used the lowest value due to the loan-to-value (“LTV”) calculation. The Encompass representative indicated that the HMDA field (HMDA.X85) uses the purchase price (field 136) or appraised value (field 356) (whichever is lower), since this is involved in the LTV calculation. Should the actual appraised value on the appraisal be used instead?
Continue Reading…