HMDA: Preparing for 2016 & the New Final Rule
On October 15th, 2015 the CFPB released a final HMDA rule to update the reporting requirements of Regulation C.
The 797-page rule will make sweeping changes to Regulation C, and dramatically expand financial HMDA reporting and compliance obligations. There are potential fair lending implications – more data means more analysis to detect potential discriminatory lending practices.
The new coverage will include closed-end mortgage loans and open-end lines of credit secured by a dwelling. There will be required reporting of many new data fields. In addition, the new rule will require “larger” HMDA reporters to report data every calendar quarter, rather than on an annual basis.
What do you need to know now? Learn HMDA reporting requirements so your financial institution begins 2016 with appropriate procedures and controls. Get practical tips for data collection and validation. What’s on the horizon? See highlights of the new rule to help prepare for changes that become effective January 1, 2018. Although implementation of the new rule isn’t for two years, there are certain impacts your financial institution may want to consider sooner rather than later.
- Overview of HMDA requirements for 2015 activity, including:
- Who reports HMDA data?
- What types of loans are covered?
- What data is reported?
- When is the data reported?
- How is the data reported?
- How to properly report data of the 26 required fields
- Common reporting mistakes and practical tips for managing the process
- Best practices for HMDA data validation
- What will the proposed rules change?
- More types of loans will be covered; the “purpose” test will be eliminated and cover nearly all dwelling-secured loans
- Data reporting is dramatically increased in these categories
- Borrower Information and Underwriting Characteristics (age, credit score, debt to income ratio, combined loan-to-value, application channel, automated underwriting system)
- Property data (postal address and location; property value, number of dwelling units in the property, construction method, manufactured housing information, multi-family housing information)
- Product Features (points and fees, borrower-paid origination charges, discount points, non-discounted interest rate, interest rate, loan term, non-amortizing features, prepayment penalty, qualified mortgage, first draw information)
- Identifiers (Universal Loan Identifier, Mortgage Loan Originator Identifier)
- Clarification and Revisions to Existing Data points include reporting the reasons for denial, occupancy type, lien priority, rate spread, HOEPA status, loan type, loan amount
- Technical changes and web-based data submission
- Privacy concerns about the public availability of the data
- Increased oversight will be required to prove the data is accurate
- BONUS – HMDA TOOLKIT
- HMDA Worksheets and Flowchart
- Summary of changes of the new rule
- Step-by-step data collection definitions and important tips to avoid mistakes for 2016 reporting
- Helpful HMDA compliance resources including checklists and a matrix of 28 types of real estate secured lending regulation requirements
Loan Operations, Loan Officers, Loan Assistants and Processors, Compliance Officers, Fair Lending Officers, and Auditors.
Susan Costonis is a compliance consultant and trainer. She frequently provides consulting services to financial institutions regarding fair lending and other compliance management issues. Her 37 year career in banking and training began with 20 years at First National Bank, an affiliate of Wells Fargo Bank, in Fort Collins, CO. Susan has been a bank compliance consultant or compliance officer in Louisiana since 1998.
During her career, Susan has successfully managed compliance programs and exams for institutions supervised by the OCC, FDIC, and Federal Reserve. She is a Certified Regulatory Compliance Manager and completed the ABA Graduate Compliance School and the Graduate Banking School of the University of Colorado. Susan regularly presents seminars to financial associations.
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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