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Complex challenges in the new HMDA rules - 2016
Kathleen Blanchard Recorded on August 09, 2016
All HMDA reporters will be affected by the revised HMDA rules effective January, 2018.
The revised HMDA rules affect all transactions with action dates in 2018, regardless of when the application was taken. That means that 12 months from now, in 2017, your institution could have applications in its pipeline that will be on the 2018 HMDA LAR and reported under the new rules.
The time to understand the rules and start planning is now. Do not think you can wait and look up instructions and definitions when you start to complete the LAR in 2018. The ability to gather data and report correctly for 2018 requires advance training and planning. This is not today's LAR with some changes in definitions. This is a major rewrite of the requirements with entirely new concepts and rules.
In prior BOL Learning Connect webinars we have reviewed changes in definitions and reportable loan types and rules for individual fields.
In this webinar, we will cover some of the more complex fields, including:
Reporting the expanded race and ethnicity fields with examples, with a surprise change from Appendix B
The one exception to the rule that modifications really are not reportable
Uniform Loan Identifier creation - a refresher
Credit score and credit score system reporting
Gross annual income - what to report in different situations
How the property value and loan to value fields work together
What the automated underwriting system and result reporting rules mean
Fields dependent upon TRID and/or ATR applicability
Affordable housing units for multi-family properties - what are they and what aren't they?
Multiple property rules - a review
Individual rules contain surprises, and the commentary and Appendices B and C are "must reads" in order to understand what and when to report. We'll break t
Kathleen Blanchard has over 32 years of experience in banking. She has developed lending and regulatory processes as a banker and consultant and presents detailed regulatory training that is very process specific. Her banking background includes commercial and private banking lending, credit review, credit policy and procedures, risk management and regulatory compliance at both community, regional and large international banks. Kathleen has been providing training and consulting services for banks, credit unions and non-bank lenders on their regulatory compliance processes, HMDA and CRA reporting, process development and training since 2006. She is a Certified Regulatory Compliance Manager and a BOL Guru for BankersOnline.com. Kathleen presents her views and advice on HMDA and CRA and other regulatory matters at her website, www.kaybeescomplianceinsights.com Since 2015, Kathleen has been delivering in depth regulatory compliance consulting and training via The HMDA Academy, a unique personalized combination of consulting, training and resources delivered online to assist financial institutions and vendors in learning and applying the revised HMDA process and rules going into effect in 2017 and 2018.
Complex challenges in the new HMDA rules
HMDA LAR Fields Effective 1/1/2018 - Comparison with Current HMDA Fields - Updated 7/17/2016
HMDA Conditional Approvals
Not Applicable Reporting for HMDA Effective 1/1/2018
Reporting Multiple Properties for HMDA 1003.4(a)(9) EFFECTIVE 1/1/2018