Compliance Alliance Question of the Week

Question:
In some cases, our bank pulls an Automated Underwriting System (AUS) report, but ultimately not used in making the credit decision. Instead, the application is manually underwritten, and those results are used to make the credit decision. For HMDA purposes, do we still have to report the AUS that was pulled?
 
Answer:
If the bank used the AUS results to evaluate the application, even if it was not used in the underwriting to make the credit decision, the bank should still report the AUS. 

1. Automated underwriting system data - general. Except for purchased covered loans
i. A financial institution that uses an AUS, as defined in § 1003.4(a)(35)(ii), to evaluate an application, must report the name of the AUS used by the financial institution to evaluate the application and the result generated by that system, regardless of whether the AUS was used in its underwriting process. For example, if a financial institution uses an AUS to evaluate an application prior to submitting the application through its underwriting process, the financial institution complies with § 1003.4(a)(35) by reporting the name of the AUS it used to evaluate the application and the result generated by that system.
https://www.consumerfinance.gov/policy-compliance/rulemaking/regulations/1003/4/#4-a-35-Interp-1