Earlier HMDA Public Data Release & Fair Lending Analysis

Be Prepared


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Calculator, pen and business document

HMDA data is a key focus of fair lending analysis.

While many institutions analyze HMDA for fair lending performance throughout the year, there are others who wait until year end or even until after submission of annual data by March 1st. The delay in analysis until after March 1 worked to some extent because data was not released publicly until September of each year. Of course, any ability to address shortcomings mid-year is lost by waiting until year end.

This will all change with the new fully automated HMDA submission process beginning with the 2017 submission in early 2018.  The current plan is for the CFPB to publish the public HMDA data quickly, possibly as early as 30 days after submission. This will be possible because all edits will be managed online and there is only one submission method, a fully automated paperless process.

HMDA data will be in the hands not only of institutions and examiners within 30 days of submission, but also will be available to community groups and software vendors who download that data into programs that provide instant fair lending analysis.

What does this mean to HMDA reporting institutions? It means that it is more important than ever to be always on top of your HMDA data and the fair lending story it tells.  If you analyze data at year end, give serious consideration to analyzing throughout the year, uncovering any shortcomings and making needed changes to improve results or at least understand reasons for performance.

Don’t wait and undertake a last minute mad scramble to review the data submitted to prepare explanations of potential disparities such as different outcomes of similar applicants, pricing differences, and geographic penetration shortcomings. All data, other than any held back from the public files, will be published for the world to see in early second quarter.

This new publication schedule will likely begin with the 2017 data submitted in early 2018, the first year under the new automated process.  We do not know at this point if there will be any grace period for 2017 data, given it will be the first year with the new process.

The 2018 data submitted in early 2019 will, of course, contain greatly expanded HMDA data, making early analysis even more important.

Contact us if you have any questions on this or other HMDA issues.

Have you checked out The HMDA Academy?  The resources go far beyond webinars and conferences. Learn about it and find out how we can help!

Multiple Dwellings to be Treated as Multifamily Collateral

Proposed Clarifications to Revised HMDA


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The CFPB issued proposed clarifications what will cause multiple dwellings securing a loan to be treated as multifamily dwellings for HMDA reporting as well as a number of other sections of the revised HMDA rule and Commentary on April 13, 2017.  The Bureau will be soliciting comments on the proposal once it has been published in the Federal Register. There are a number of large and small changes proposed.  One major change is the treatment of 5 or more individual dwellings of fewer than 5 units as multifamily collateral.

The Bureau believes that such a loan should be reported as secured by a multifamily dwelling. As with loans that are secured by multifamily dwellings in one location, the information that would be excluded from reporting under revised § 1003.4(a), such as the debt-to-income ratio discussed above, might also not be easily available, relevant, or useful for loans secured by five or more separate non-multifamily dwellings in more than one location. Consequently, to facilitate implementation and ensure the relevance and usefulness of the data collected, the Bureau proposes to add language to comment 2(f)-2 making clear that a loan secured by five or more separate dwellings in more than one location is a loan secured by a multifamily dwelling and providing an example. The Bureau solicits comment on this added language.

To implement this clarification, the revision to the Commentary on the definition of Dwelling is proposed to state:

“In addition, a loan secured by five or more separate dwellings in more than one location is a loan secured by a multifamily dwelling. For example, assume a landlord uses a covered loan to improve five or more rental property dwellings located in different parts of a town, and the loan is secured by those properties.  The loan should be reported as secured by a multifamily dwelling.”

A loan secured by or proposed to be secured by such a group of dwelling would follow multifamily rules when completing the HMDA LAR. These multiple dwellings will not necessarily be treated as multifamily for Community Reinvestment Act purposes, which will present challenges for financial institutions subject to CRA.

The complete proposed clarification can be found at this link.

We will review other proposed changes in future articles over the new few weeks. Two of the additional major changes are adjustments to reporting of race and ethnicity and the welcome exemption for builder construction financing.

Watch for the proposal in the Federal Register and submit your comments on the suggested changes.

Action Date for HMDA Transition

Here are the citations


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Is It Application Date or Action Date for HMDA in 2018?

Recently, a number of questions have been asked about whether the revised HMDA rules going into effect 1/1/2018 apply only to applications taken in 2018.

Following normal HMDA reporting practices, and the instructions in the preamble to the final HMDA rule published in the Federal Register of October 28, 2015, the revised rule applies to all applications with an action taken date of January 1, 2018 and onward. Refer to Page 22657 of the Federal Register:

“This final rule applies to covered loans and applications with respect to which final action is taken beginning on January 1, 2018. Data on these covered loans and applications are submitted to the appropriate Federal agency pursuant to § 1003.5(a) beginning on January 1, 2019. For example, if a financial institution described in 2(g) of this part receives an application on January 1, 2018 and takes final action on that application on March 1, 2018, data about that application will be collected and recorded pursuant to § 1003.4, and submitted to the appropriate Federal agency by March 1, 2019 pursuant to § 1003.5(a). Similarly, if a financial institution described in 2(g) of this part receives an application on December 1, 2017 and does not take final action on that application until January 1, 2018, data about that application would be collected and recorded pursuant to § 1003.4 and submitted to the appropriate Federal agency by March 1, 2019 pursuant to § 1003.5(a).441 The final rule also applies to purchases that occur on or after January 1, 2018. For example, a financial institution described in 2(g) of this part that purchases a HMDA reportable loan on February 1, 2018 would collect and record data about that purchase pursuant to § 1003.4, and submit the data to the appropriate Federal agency by March 1, 2019 pursuant to § 1003.5(a).

441The Bureau understands that final action taken on an application may not occur until a few months after the application date. A financial institution may receive an application at the end of a calendar year but may not determine the final disposition of the application until the following calendar year.

Why Isn’t the Revised Rule Implemented Only for Applications Taken in 2018?

HMDA reporting involves an aggregation of data for applications with final action taken in a single calendar year. Applying the new rule only to applications taken in 2018 would leave applications taken in 2017 (or previously) and final action in 2018 unreported. There would have to be a special filing for those transactions, and what if some were not originated until 2019? That would be yet another separate submission. What would that do to fair lending analysis?

It truly makes more sense to apply the rule based upon action date.

Some have asked why HMDA reporting is not based on application date.  If HMDA data was gathered by application date, you would be including applications that have not yet reached a final processing stage and therefore would not yet have all required data available (including an action taken type or action taken date).  Until final action is taken, many aspects of the transaction can change including applicant names, loan amount, collateral address, interest rate, etc. Additionally, reported transactions must be geocoded using the same annual year census data in order to allow for meaningful comparisons and analysis.

TRID implementation could be done by application date because the TRID rules are applied on an application by application basis, and not aggregated together systemically in the manner of HMDA data.

Historical Reporting

HMDA has always been reported by action date.  The current HMDA Getting It Right Guide states (Page 7):

“A LAR for a given calendar year must contain all reportable applications that reached final action (e.g., origination of a loan, denial of an application) in that year, regardless in which year the application was submitted. The LAR should exclude applications that have not yet reached a final action; those applications should appear on the LAR for the calendar year in which they reach final action.”

Planning for the Transition

Transitioning to the new HMDA rule will take planning and pipeline management.  Be prepared to capture the new fields on applications taken prior to 2018 and already in the pipeline.  As year end 2017 approaches, it might be possible to finalize open applications prior to year end provided regulatory and safety and soundness considerations are observed (don’t deny all open applications on December 31, 2017!) Some applications simply will not be ready for final action.  For those, be prepared to have all data available to report for the revised HMDA LAR.

There are nine months left in 2017 – start planning for the transition.

Ethnicity, Race and Sex Transition Rule

There is a special transition rule for using and reporting the expanded ethnicity and race information on applicants. The CFPB has issued a chart that explains the process well. The aggregate ethnicity data means “Hispanic or Latino” or “Not Hispanic or Latino”.  Aggregate race refers to the major categories now in use (American Indian or Alaska Native; Asian; Black or African American; Native Hawaiian or Other Pacific Islander; and White).

Disaggregated data refers to the subcategories that can be selected by applicants for 2018 reporting, such as Mexican, Puerto Rican or Cuban, for ethnicity.

For 2017, only aggregate data will be reported even if the financial institution voluntarily collected the disaggregated data.  The disaggregated data is not “official” until 2018.

Race Ethnicity Use Chart

 

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Legal Entity Identifier (LEI) for HMDA

Time to Order


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Who Needs an LEI

LEI questions are being asked frequently!

All HMDA reporters will have to obtain a Legal Entity Identifier (LEI) in order to use the new HMDA platform as of 1/1/2018. All HMDA reporters will use the new HMDA platform, even if your institution uses vendor software to initially prepare your data.

Therefore, every institution that will be a HMDA reporter in 2018 must obtain an LEI. You should get it on your agenda now to avoid an end of year rush.

The institution that is submitting a HMDA file needs an LEI, a parent company’s LEI cannot be utilized. The LEI must be specific to the HMDA reporter submitting data.

Why Do We Need an LEI

The CFPB chose to use an existing legal entity numbering system to replace the various IDs currently in use as Respondent IDs for HMDA reporting.  The LEI process was not developed just for HMDA.

The Global Markets Entity Identifier (GMEI) utility is DTCC’s (Depository Trust & Clearing Corporation) legal entity identifier (LEI) solution. The solution was designed to create and apply a single, universal standard identifier to any organization or firm involved in a financial transaction globally and was developed in response to the financial crisis of 2008- 2009 after governments and regulators called for new financial market regulation.

The CFPB did not “cook this up” solely for HMDA!

Ordering an LEI

Use the following website to order the LEI:

GMEI Utility

Is Your Legal Entity Already Registered?

Check first to see if your firm is already registered.  Many are, for various reasons.

You can search your firm’s name by clicking on the search symbol at the top right and entering key words. The search box will appear when you click on the magnifying glass.

picture of legal entity identifier search

 

Make use of the Help section and manual and FAQs.  Those can be accessed at the top left under Help and Documents.

LEI Help section

 

Cost to Register for an LEI

The total cost to initially register for an LEI is $219, the $200 fee and a $19 surcharge.  Annual renewals are $100 plus the $19 surcharge.

Payment is made on the site; payments come through as an international transaction because the GMEI is in Europe.

Completion of the Transaction

The User Manual, in the Help section, will walk you through the process.

Get it done now and have one less thing to remember in this very busy year!

 

Just Getting Started with the Revised HMDA Rules?

Advice on First Steps


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We are now in the last 11 and 1/4 months before the revised HMDA rules go into effect on January 1, 2018.

If you are just beginning to look at the new rules, you have a big task ahead of you. There are several tasks that need to be done before diving into the requirements for reporting individual fields:

• If the financial institution is a smaller reporter, determine if it is a mandatory reporter for 2017, and again for 2018. There are new loan volume thresholds that can exempt some smaller reporters (depository institutions only in 2017 and all lenders in 2018). You can review a lesson on the new volume thresholds here.

• Review the Small Entity Compliance Guide, no matter the size of your financial institution. It provides a good overview of the changes but is not a substitute for learning the regulation and the Commentary.

• Work with the lending divisions and product areas at your financial institution to become familiar with the application and underwriting process and develop data on where specific data is stored (e.g., credit scores, loan to value, property value, automated underwriting system results, etc.), and how it will be transferred to the HMDA LAR. You can opt in to this blog for regulatory and training updates and receive a project plan plus some additional HMDA charts. The link is on this page on the right.

• Lastly, fully understand what properties are reportable for HMDA beginning in 2018. The rules have changed; there are new exclusions from the definition of dwelling and new rules for treatment of agricultural loans and agricultural properties with dwellings, and revised rules for mixed use properties that affect what is considered a dwelling.

Once it has been determined that the financial institution is a HMDA reporter, and there is an understanding of what properties are dwellings for HMDA, then begin to go through the revised rule and Commentary and lastly the Filing Instruction Guide (FIG). The FIG contains additional information, including a few instructions that are not in the regulation or Commentary at this time.

The Commentary is mandatory reading; if you only review the regulation itself, you will not understand the actual reporting requirements or definitions. The detailed requirements (what, when and how) are primarily contained in the Commentary. The Commentary is available at the CFPB’s eregulation site, where it is linked to the regulation, and also at BankersOnline. Make sure you read the rule for the proper reporting year.

If you want help with all of this work, consider enrolling in The HMDA Academy.

CFPB Posts 2017 HMDA LAR Tool

The Consumer Financial Protection Bureau has published an HMDA formatting tool for 2017 HMDA. The tool is available at this link.

The tool allows for data entry directly into Excel, including transmittal sheet data. When the time comes to upload to the data to the HMDA platform, simply click the Create LAR File button in the top left cell! A macro will then create the properly formatted text file for upload.

The formatting tool has the added benefit of pop-ups with the possible codes for each field. I think those who relied upon the FFIEC software will find this Excel tool very user friendly and helpful. It is ready to use as soon as you download it.

Mixed-Use Properties and HMDA

Changes to Treatment under HMDA


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There is a subtle but important change in the revised HMDA rules regarding mixed-use properties.

Agricultural Exclusion

You probably already know that, under the revised 2018 rules, a loan secured by a dwelling that sits on land used primarily for agricultural purposes is an excluded transaction and not HMDA reportable no matter how the loan proceeds are used. This exclusion can be found in the revised Commentary at §1003.3(c)(9).

Non-Farm Mixed-Use Properties

For non-farm mixed-use transactions, there is a similar change that is achieved in a different manner.

The comment at 1003.2(f)-4 regarding mixed-use properties tells us that “A property used for both residential and commercial purposes, such as a building containing apartment units and retail space, is a dwelling if the property’s primary use is residential.”

Not a Dwelling

If a property with a primarily residential use is a dwelling, a property with a primarily non-residential use is not a dwelling. A loan must be dwelling secured to be HMDA reportable. (The optional non-dwelling secured home improvement category is going away in 2018.)

The comment at 1003.2(i)-4 goes on to say:

“A closed-end mortgage loan or an open-end line of credit to improve a dwelling used for residential and commercial purposes (for example, a building containing apartment units and retail space), or the real property on which such a dwelling is located, is a home improvement loan if the loan’s proceeds are used either to improve the entire property (for example, to replace the heating system), or if the proceeds are used primarily to improve the residential portion of the property. An institution may use any reasonable standard to determine the primary use of the loan proceeds. An institution may select the standard to apply on a case-by-case basis.”

This means that if your property is not a dwelling, such as a mixed-use property with a primarily non-residential use, loans secured by such a property will not be HMDA reportable no matter the use of loan proceeds.

Where does this leave us?

1. Properties secured by dwellings on primarily agricultural land are not HMDA reportable due to the exclusion for agricultural use.
2. Properties secured by a primarily non-residential property are not HMDA reportable because they are not defined as a dwelling.

The same result was reached by two different paths.

This is a change from current rules which did bring loans secured by such collateral into HMDA reporting if improvements were made to the entire property or to the residential portion. Under this revision, the property is not a dwelling and any loans secured by such a property will not be reportable for HMDA regardless of use of proceeds.

“Property” is not limited to a single structure

Also, it is important to understand that a “property” does not mean just a single structure. A primarily non-residential property could consist of several structures with several being non-residential and one residential. Using a test such as square footage, the multi-structure property could very well be non-residential and loans secured by such a property will not be dwelling secured.

If you need help getting up to speed with the new HMDA rules, contact us! With the HMDA Academy, you get immediate access to 5 recorded webinars on the new rules and all future webinars through June 2019. The next webinar is scheduled for December 13, 2016.

HMDA Process Changes Coming in 2017

All HMDA reporters are affected by these changes!


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2017 HMDA Process Changes

Are you ready for the new HMDA process in 2017?

I have been asked many times recently if it is true that there are HMDA changes coming in 2017. The answer is yes! Please share this article if you have any peers in the industry who might not be aware that there are changes for 2017.  So much has been heard about the major changes coming in 2018 that many have not focused on 2017.

The rules regarding data to be reported remain the same in 2017, but the software, file format and submission process are all changing. This affects every HMDA reporter in some way, even those using vendor software.

HMDA Software

The familiar FFIEC HMDA software is going away after the 2016 HMDA submission.  For any transactions with an action date in 2017, there will be a new online browser based HMDA platform that will be used to run edits and submit HMDA data.  The FFIEC downloadable software will no longer be used after the 2016 submission.

If vendor software is not used, an institution will maintain data in a spreadsheet and upload it to the HMDA platform after conversion to a pipe delimited file using a CFPB provided conversion tool.

Web submission via the HMDA platform will be the only submission method.  There will be no mailing of paper loan application registers or disks or CD-ROMs, nor will encrypted files be emailed by financial institutions or their vendors. The 2016 submission in 1st quarter 2017 will be the last year for those filing methods.

All edits and error checks will be run online, including the macro edits that are currently emailed after a HMDA file is submitted.  Macro edits will be presented online and the file cannot be submitted until all edits are resolved. This means processes must change to allow time to review and respond to all macro edits prior to submission.

Registration and Certification

An online certification by an individual authorized to certify to the accuracy and completeness of the data will be required prior to submission.

All HMDA reporters will be required to register to access the CFPB HMDA platform. Information on the registration process will be issued at a later date.

Availability of the HMDA Platform

The new HMDA software is expected to be made available in the summer of 2017.

Many HMDA reporting institutions run monthly or quarterly edits on their data as part of the HMDA quality control process and to comply with the requirements to have the HMDA loan application register available within 30 days of each quarter end. To assist with that process prior to the release of the new platform, the CFPB is planning to provide a solution to be used until the full HMDA platform is released. More information on the edit solution is expected in January 2017.

CFPB Resources

You can keep up to date with the technology changes at this link at the CFPB website.

The Filing Instructions Guide (FIG) for 2017 is available at this CFPB link as well as at the FFIEC site under HMDA file specifications.

Questions?

If you have questions, you can contact me at this link.

Park Models, Tiny Homes and HMDA

Are all tiny homes the same under HMDA?


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Park Models and Other Tiny Homes and HMDA

I have been asked many times if tiny homes are HMDA reportable under both current HMDA rules and the revised rules going into effect 1/1/2018. I have also been asked how to treat a park model tiny home if the wheels are removed and it is placed on a foundation.

The answer depends upon the specific situation. More information is needed than simply referring to the collateral as a “tiny home”.

This article will answer these questions and discuss other aspects of tiny homes and recreational vehicles.

Park Model Homes

Some “tiny homes” are park model homes. A park model is a type of recreational vehicle built on wheels; these are specifically excluded from the definition of dwelling under the revised HMDA rules. They are excluded because park model homes are not manufactured homes built in compliance with the HUD construction code. They are legally a recreational vehicle even when the intention is to leave it in one place.

You can read about park model homes here.

Under current HMDA rules, in effect until 12/31/2017, recreational vehicles are not dwellings according to the Commentary for the definition of dwelling at 1003.2. I believe you should include park models in that category because they are classed as recreational vehicles, not subject to either site built building codes or manufactured home building codes. Many local zoning laws restrict use of park models and other recreational vehicles as full time residences.

From the current Commentary: “1003.2 Dwelling – 2. Exclusions. Recreational vehicles such as boats or campers are not dwellings for purposes of HMDA. Also excluded are transitory residences such as hotels, hospitals, and college dormitories, whose occupants have principal residences elsewhere.”

Under revised HMDA rules effective 1/1/2018, park model recreational vehicles are specifically excluded. The revised Commentary states: “EXCLUSIONS. Recreational vehicles, including boats, campers, travel trailers, and park model recreational vehicles, are not considered dwellings for purposes of § 1003.2(f), regardless of whether they are used as residences. Houseboats, floating homes, and mobile homes constructed before June 15, 1976, are also excluded, regardless of whether they are used as residences. Also excluded are transitory residences such as hotels, hospitals, college dormitories, and recreational vehicle parks, and structures originally designed as dwellings but used exclusively for commercial purposes, such as homes converted to daycare facilities or professional offices.”

Site Built Tiny Homes

Tiny homes can also be site built, some on permanent foundations, others built on skids to allow future moves to another “permanent site”. These are not park model recreational vehicles.  An applicant could construct a tiny home on land that they own. Review this article on site built tiny homes.

A site built tiny home on a permanent foundation is simply a small home and will be subject to HMDA when used as a dwelling. That is the same under current (pre-2018) and revised (effective 1/1/2018) rules; HMDA has no size standards. Of course, the house must meet local zoning laws to be a legal dwelling; that is an important factor for a financial institution to consider for a structure to be acceptable as collateral.

There are many complexities involved in building site built tiny homes. How they are taxed and treated under local zoning and tax laws can hinge on whether they are eligible for permanent electrical, water and sewer hookups.

Many city and town ordinances have very specific requirements, such as Albuquerque, NM.

Tiny Homes as Cooperatives

There are some tiny home communities that are set up as cooperatives. This particular community in Oregon is intended for low and moderate income, but the concept could work for any income level.

Can a Park Model RV Be Changed to a Site Built Home?

I have been asked a number of times if a tiny home on wheels can be changed to a site built home.

If the wheels are removed and the home is attached to a permanent foundation, you must consider the same factors as a manufactured home that has been revamped. You will have to consider how the home is appraised, zoned, insured, etc.  Those factors can be influenced by whether the home meets local building codes. It could end up as an illegal structure that has been made more difficult to move. If it is located in a rural area without building codes this will be less of a problem.

Review my recent article on whether a manufactured home can be treated as a site built home.  The same concepts apply.

HUD states in its FAQs that a home built as a park model cannot later be changed to a manufactured home category, with a HUD label.

“I have a park model home and have made upgrades to my home. I was told I need a HUD label. How do I get one?

Regardless of the upgrades made to your park model, it is not possible to obtain a HUD label on any structure that was not produced and inspected as a manufactured home in accordance with HUD’s Manufactured Home Construction and Safety Standards and Regulations during its original construction. You may contact the Recreational Park Trailer Industry Association  http://www.rptia.org for additional information and resources regarding park model homes.”

Conclusion

Overall, decisions collateral must be made on a case by case basis, words every compliance officer and lender hates to hear, but there is no one size fits all.

Of course, HMDA rules do not necessarily carry over to Regulation Z when determining if a loan is secured by a dwelling. Careful training of staff to accurately report for HMDA while also complying with other regulations is critical.

HMDA Academy link to sales page

Time to Get Busy with the Revised HMDA Rules!

15 Months Until 1/1/2018 Implementation Date!


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Have you started working on HMDA yet?

Here we are, almost in the 4th quarter of 2016, just a little over 15 months from implementation of the revised HMDA rules. I know that many financial institutions have been postponing working on the revised rules because they have been busy living through the first year of TRID and implementing the Military Lending Act. If HMDA has been on a back burner, it is time to start thinking about it.

2017 Changes

There are changes, including revisions to the file creation and submission process, that go into effect January 1, 2017 for 2017 data.

You can read about the 2017 changes in this recent article, linked here.

Planning for 2018

To prepare for 2018, there is a lot to be done to get started. Start by becoming familiar with the new LAR fields.  Check out the 2018 Filing Instructions Guide (FIG)  for a quick view of what information is required.

2018 Filing Instructions Guide

Learn the revised definitions and rules. Review the regulation, commentary and analysis at the CFPB eregulations site via this link.  You want the Regulation C amendment effective 1/1/2018.

You can also find the regulation and commentary at BankersOnline at this link. The BankersOnline site provides the current regulation, followed by the revised regulation in a red font, then the current commentary followed by the revised commentary also in red font.

Project Plan

To help with your planning, you can access a template  to help you develop your project plan at these links. If you have trouble with the download, let me know.

Project Plan Template Word Version

Project Plan Template pdf

Determine where the information needed for the HMDA submission is obtained. Does your institution use multiple systems and processes? You have to consider all of those in order to plan appropriately.

If you use a vendor application origination system, find out the vendor’s plans to comply with the revised HMDA regulation. Determine where the needed data is so that it can be supplied to the origination system once the vendor provides access. The core system may have much of the data (collateral values, credit scores, etc.) but it won’t usually have the data for non-originated applications. In any case, test the data for accuracy for HMDA reporting. You will need to know credit scores and scoring systems, automated underwriting systems and results (and understand the complex rules), combined loan to value and collateral value, and several pieces of information from the TRID closing disclosure – just as a sample!

If you have a manual process, locating sources for all data is even more important because scrambling on a loan by loan basis will not be efficient and will lead to errors.

More Assistance

If you want more assistance including training, charts explaining the various requirements, and answers to your specific questions, then consider membership in the HMDA Academy.  There are three webinars previously presented recorded and available for all members.  More HMDA Academy webinars are planned for the Fall, covering business purpose loans, multi-purpose loans, multiple collateral loans, and more.  These webinars will be available individually, but it is more cost effective to pay one fee for the HMDA Academy and have the added benefits of charts and consulting assistance by way of submitting your questions. Every question gets careful consideration and follow up, including emails and calls if needed.

You can read about the HMDA Academy at this link, and can contact me with questions or for more information by clicking here.