If you are a HMDA reporter, you also need to determine almost immediately if the application is a HMDA reportable application or an application for 1071 so you know what to collect for demographic data from the applicant.

You are correct if I understand your question. That’s one of the main points I was making during the webinar. A lender will need to determine early in the loan process if the application is a covered application for a covered transaction that is not excluded under 1071.