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. The modifications to HMDA were massive and many financial institutions are still dealing with the challenges of collecting data under the burdensome new requirements. This program provides the top 15 issues that may have been overlooked when implementing the new HMDA requirements.
This two-hour webinar provides insight into the muddy areas of HMDA which may result in incorrect entries in the data fields on the HMDA LAR and lead to violations. 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 beginning in 2018 and how the coverage rules may change in future years;
- Challenges in determining if a structure is considered a dwelling, like a manufactured home versus mobile home;
- When you should report a mixed-use property 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 your financial institution can exempt closed-end mortgage loans and open-end lines of credit in 2018 and in future years;
- The purpose of the Legal Entity Identifier and its impact on the Universal Loan Identifier;
- Explanation of the census tract data field and forthcoming geocoding tool available from the CFPB;
- Detailed requirements related to the collection of ethnicity, race, and sex of applicants and borrowers;
- Challenges with reporting the 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
- Steps to identify and eliminate reporting errors and thereby avoid penalties.
Top 15 Issues With the New HMDA Rules
Questions and Answers