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It has been five years since overhauled HMDA Regulation CC became effective, and Congress, the courts, and the CFPB have made some changes since then. The rules are still complex and confusing, requiring pages of Official Interpretations, along with annual reporting guidance, a Small Entity Compliance Guide, Guidance on collection and reporting of ethnicity, race and other demographic information … the list of challenges goes on. Yet, even with all the compliance guidance on HMDA, banks large and small are getting fined for submission of incomplete or incorrect data. And there continue to be misunderstandings on basics, such as when an application or loan is reportable.
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.
The program explores:
- Which institutions are covered by HMDA and Regulation C.
- 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 now and in the future.
- 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 – A review of the A Regulatory and Reporting Overview Reference Chart for HMDA Data Collected in 2022.
The program is designed for loan officers, compliance officers, loan processors, clerks, and auditors.
Questions and Answers