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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? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

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?

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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.