The New HMDA Rule: Implementation Challenges
After a long wait, the CFPB finally issued its new HMDA rules.
The new rule takes effect in phases: first HMDA’s coverage increases to include more institutions; then starting in 2018 the real fun begins: new rules around what types of loans are covered, and many more data elements (110 to be exact).
As well, the submission and disclosure processes will change, to the new CFPB online method. 2018 seems a long time into the future, but there is much to be done. Now is the time to start your game plan, both in the compliance and technology areas.
- Details of the new coverage rules – who collects and submits information, and when
- What types of loans are reportable now, and changes happening for collecting 2018 data
- The new dwelling-secured loan standard – what does this impact?
- Changes in the commercial loan area
- How to handle HELOCs
- New LAR fields – moving to 53 fields, but with many additional data requirements
- New categories of reporting, including information on the property, loan type, and loan features; plus identification information
- Changes on how GMI is reported
- Changes to the submission process
- Quarterly reporting for some institutions
- How the public obtains HMDA information changes
Loan officers, managers, and processors, compliance and fair lending officers, auditors, counsel, and anyone else with HMDA-related responsibilities, including data collection, reporting, analysis, and disclosure.
Carl Pry is a Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) who is a Managing Director for Treliant Risk Advisors in Washington, DC. Through his working career, as well as through his experience as a banking attorney and officer, he has provided a variety of regulatory compliance and financial performance services to financial institutions and other clients throughout the country. He has written extensively regarding consumer and commercial compliance, tax, audit, and financial institution legal issues, and is a frequent contributor to and currently serves on the Editorial Advisory Board for the ABA Bank Compliance magazine. He has spoken at scores of banking, compliance, and state bar associations, and has conducted training sessions for financial institutions across the country.
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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