For HMDA reporting purposes, do we need to consider the Illinois High Risk Home Loan Act when reporting whether a loan is a HOEPA loan?

—

by

No, you do not need to consider the Illinois High Risk Home Loan Act’s requirements when reporting for HMDA purposes. The HMDA reporting instructions require you to report whether a loan is subject to the federal Home Ownership and Equity Protection Act of 1994, without reference to state law.