Top 15 Issues with HMDA

The world of HMDA changed dramatically on January 1, 2018. The final rules implementing changes to Regulation C required by the Dodd-Frank Wall Street Reform and Consumer Protection Act were generally effective on that date. Further issues arose on May 24, 2018 when Congress passed the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA).

The 2018 modifications to HMDA were massive and many financial institutions are still dealing with the challenges of collecting data under the burdensome new requirements. The partial exemption provisions resulting from EGRRCPA were a blessing and a curse. This program provides the top 15 issues that may be undermining your HMDA compliance efforts.

During 2019:

  • An advanced notice of proposed changes to Regulation C was published on May 8, 2019.The ANPR solicits comments about the costs and benefits of collecting and reporting the data points the 2015 HMDA Rule added to Regulation C and certain preexisting data points that the 2015 HMDA Rule revised. Comments on the APRN were accepted until July 8, 2019.
  • A proposed rule was published on May 13, 2019. For closed-end mortgage loans, the NPRM proposes two alternatives that would permanently increase the coverage threshold from 25 to either 50 or 100 closed-end mortgage loans. For open-end lines of credit, the NPRM would extend for another two years the current temporary coverage threshold of 500 open-end lines of credit. Once that temporary extension expires, the NPRM would set the open-end threshold permanently at 200 open-end lines of credit. The comment period on the NPRM has been extended from June 12, 2019 to October 15, 2019.

This two-hour webinar provides insight into the murky areas of HMDA which may result in the failure to report the appropriate loans on the LAR or errors in reported data fields. Participants receive a detailed manual that serves as a handbook long after the program is completed.

Covered Topics

  • Which institutions are covered by HMDA and Regulation C beginning in 2018 and how the coverage rules may change in future years;
  • Challenges in determining if a structure is considered a dwelling, such as a manufactured home versus a mobile home;
  • When a mixed-use property is reported as a dwelling;
  • How to report multifamily residential structures, such as manufactured home communities;
  • Clarification on reporting home improvement loans;
  • HMDA reporting requirements for construction and permanent financing versus TRID requirements;
  • The expanded clarification on temporary financing;
  • Whether a financial institution can exempt closed-end mortgage loans and open-end lines of credit in 2019 and in future years;
  • The purpose of the Legal Entity Identifier and its impact on the Universal Loan Identifier;
  • Proper reporting of property-related fields;
  • Detailed requirements related to the collection of ethnicity, race, and sex of applicants and borrowers;
  • Challenges with reporting the interest rate and rate spread;
  • Where to locate specific fees from the Loan Estimate and Closing Disclosure required to be reported on the HMDA LAR;
  • When and how to report the use of an Automated Underwriting System; and
  • The partial exemption contained in the Economic Growth, Regulatory Relief and Consumer Protection Act.

Bonus item - Coverage of the proposed 2019 revisions.

Who Should Attend?

The program is designed for loan officers, compliance officers, loan processors and clerks and auditors.