RMLA Questions

Questions about the RMLA fields on MCR v6.

Q. What amount do I report under the application amount – the initial amount on the application or the amount the application closes if it changes?
The initial amount on the application should be used when completing the application data on the MCR. If the application amount changes prior to closing, use field AC065 to capture those changes.
​Q. What do I report as application amount if the loan was withdrawn or denied prior to the loan amount being known?
Even if no loan amount was applied for prior to the application being withdrawn or denied, if credit is sought, an application amount needs to be included. For MCR filing purposes, $1,000 should be reported for the application amount when the application amount is unknown.
Q. What do we report under Net Changes in Application Amount (decreases should be reflected as a negative)? Application amounts may have changed from applications received previous quarters and Loans Closed and Funded reported under AC070 for the quarter are not always the same loans reported under Applications Received (AC020) in the quarter.
Figure 1. Example: Net Changes in Application Amount flows within a single quarter or over two plus quarters

For one loan:

Initial application amount (reported on AC020) when application is received: $100,000
Changes to the loan during the quarter (Q1) (report in AC065) - $20,000

Each application needs to be tracked and add all the changes for ALL loans into a net figure reported under AC065. If the loan application used in the example above, closes within the quarter, report that change to the loan amount in AC065.

If that loan application moves into the next quarter, it moves over at the lower net amount of $80,000. If another change to the application amount occurs during the following quarter, that change is reported the same way as in the above example for AC065.

Figure 2. Example: If another change to the application amount occurs during the following quarter:

For example:

Initial Application amount (reported on AC020) when application is received (Q1): $100,000
Changes to the loan during the quarter (Q1) (report in AC065) (Already done in Q1) - $​​20,000
Changes to the loan amount during the quarter (Q2) (report in AC065) $ 10,000

If the loan application in the example used above closes in Q2, report the change to the loan amount in AC065.

If that loan app moves into the next quarter, it moves over at the higher net amount of $90,000.

You need to continue tracking the loan amount until the loan closes.

Q. What do I include in the Broker Fee and Lender Fee fields of RMLA Section I?
Include all fees that your company has collected and retained. Examples include, but are not limited to, origination fees, application fees, and yield spread premiums (YSP). Do not include pass through fees. Note that compensation paid to MLOs is not considered a pass through fee.
Q. When reporting activity information on a RMLA component by state, is this based on the location of the property?
Yes, the activity information is based on the location of the property and reported by state.
Q. Does private money lending for any loan type on the MCR need to be included on the RMLA?
Yes, all residential mortgage loans must be accounted for on the RMLAs regardless of the source of funds.
Q. Does my company have to report loans on unimproved land or construction loans (other than construction-permanent loans) or other temporary financing on the MCR?
No, these types of transactions are not required to be reported at this time. As a reminder, construction-permanent loans MUST be reported.
Q. Our company does not collect fees directly from the borrower. Do I have to report fees I receive from someone other than the borrower?
Yes, you must report all fees received, other than pass through fees, regardless of whether they come from the borrower, lender or other party. At a minimum, these fees are reported in AC600, AC610, AC620 and AC630 as appropriate.
Q. Does MLO information be entered manually?
No, MLO information can be uploaded in conjunction with the XML upload or uploaded via a CSV upload file.
Q. What if my company had no MLOs during the reporting period?
If you did not conduct any activity during the reporting period, then the MLO section can be left blank. If your company reported loan activity and you didn't have any MLOs in that reporting period, then you should enter one of the control persons (MU2 persons) as the person conducting the activity with an explanatory note.
Q. What if we no longer employ an MLO but did in the reporting quarter − do we list them on the MCR?
Yes, you must list each MLO you employed that closed loans during the reporting quarter in each state whether or not you employ the MLO when you submit the MCR filing.
Q. We have loans in our portfolio that were originated before the QM rules went into effect. How do I report those loans (that could be either QM or non-QM) in my assets?
Loans that were originated prior to QM regulation can be reported on line AC940 (Not Subject to QM) in the RMLA component of the Standard and Expanded MCR, and on line A060W3 (Not Subject to QM) in the financial condition component of the Expanded MCR.
Q. How should my company report a construction loan if it changes to a non-construction loan?
The construction loan will start as a non-QM loan, but once it changes over to a non-construction loan, it can be placed in the QM portfolio or category if it meets the requirements.