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During the CMG Meeting on September 30th it was mentioned that Bank’s may start to utilizing the new URLA anytime between January 1, 2017 and the implementation date of January 1, 2018. However, Fannie Mae and Freddie Mac state that “Lenders may begin using the redesigned URLA on January 1, 2018”. Could you please clarify if we are able to utilize the new URLA prior to the implementation date of January 1, 2018?
Thank you!
We apologize for overlooking your question earlier.
You may begin using the new URLA on January 1, 2017 but it is not required. Collection of the expanded HMDA information is required as of January 1, 2018. The CFPB published a notice of approval allowing the collection of the new expanded HMDA data in 2017 which means you can use the new URLA beginning January 1, 2017. You can access the CFPB’s notice here: https://www.federalregister.gov/documents/2016/09/29/2016-23555/status-of-new-uniform-residential-loan-application-and-collection-of-expanded-home-mortgage.
Jack also issued a blog article in this topic. You can access the article here: https://mycomplianceresource.com/regulation-b-and-the-new-uniform-residential-loan-application/.
If you are selling loans to investors you should check with the investor to see if they will accept the new application prior to the mandatory compliance date of January 1, 2018.
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