HMDA 2018 Challenges with Taking Applications Part I – Consumer Applications
How should you begin to prepare for these sweeping changes?
HMDA reporters must follow the new rules for applications when final action is taken on or after January 1, 2018.
MOST of the required information for consumer loans comes from the FNMA 1003 application. A redesigned URLA (Uniform Residential Loan Application) form was released August 23, 2016 and may not be used until January 1, 2018. While the reporting process may be more streamlined in the secondary market area, there will be significant changes requiring extensive training and internal controls for not only traditional mortgages but other types of applications. The “dwelling secured” standard was generally adopted for closed-end loans and lines of credit. What type of application form should be used for a line of credit to consolidate debt that is secured by a dwelling? What if the collateral is a “mixed use” property? How will your employees know when the applicant and co-applicant should be asked to identify their ethnicity, race, and sex? Do you collect any information for additional co-applicants or guarantors?
Will the application forms you are currently using provide all the required fields for the new reporting requirements?
There are approximately 81+ “working days” from this presentation until January 1, 2018. There are very few parts of the existing rules that will remain unchanged and there are 110 data elements in the new rule. Will you be ready for these extensive changes? Attend this session and learn more about application processing for consumer loans under the new rules and gain valuable tips that will help your bank prepare for 2018.
(Note: Commercial Applications will be covered in Part 2 on November 14, 2017)
- Coverage issues – Which CONSUMER applications are covered loans that require data to be collected at the time of application?
- What data will be reported about the applicant? What data will be excluded?
- Learn about special rules for prequalification versus preapprovals
- What is the correct application date?
- Identifying the correct loan purpose – there are FIVE options and rules for multi-purpose loans
- Learn how to properly request and record “demographic” information and the process for applicants to “self-identify” under sub-categories for ethnicity and certain race categories.
- What does the front-line need to know about these changes?
- The pre-approval rules have been expanded and changed
- Suggestions for potential problems with collecting, reporting, and validating the data fields for “applicant” and applications in these required fields and understanding when they may NOT be reported:
- Debt-to-income ratio
- Credit score
- Automated underwriting system
- Application channel
- Reason for denial
- Application date
- Preapproval request
- Ethnicity, race and sex
- Disaggregation of ethnicity and race
- Explanation for 13 KEY points about data collection including loan applications that begin in 2017 but final action is taken on or after January 1, 2018.
This informative session is designed for lenders, personal bankers, loan assistants and processors, loan operations staff, compliance officers, fair lending officers, IT staff, and auditors.
Susan Costonis is a compliance consultant and trainer. She specializes in compliance management along with deposit and lending regulatory training.
Susan has successfully managed compliance programs and exams for institutions that ranged from a community bank to large multi-state bank holding companies. She has been a compliance officer for institutions supervised by the OCC, FDIC, and Federal Reserve. Susan has been a Certified Regulatory Compliance Manager since 1998, completed the ABA Graduate Compliance School, and graduated from the University of Akron and the Graduate Banking School of the University of Colorado. She regularly presents to financial institution audiences in several states and “translates” complex regulations into simple concepts by using humor and real life examples.
Institute of Certified Bankers: Visit http://www.icbmembers.org/login.aspx for instructions regarding self-reporting. Estimated credits: 2.5 CE Credits
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