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I need some clarification on the loans that do not currently meet the HMDA purpose.
Let’s say we have a loan in 2017, that is Home Equity purpose Vacation, that is dwelling secured. Do we report those in 2018? And if so how? Since they didn’t meet the current rule for collecting GMI for example.
I keep reading conflicting infoThe new HMDA requirements apply to closed end mortgage loans or open-end lines of credit that are secured by a dwelling, unless an exception has been met. The transaction you describe in your question appears to be a covered transaction under the new rules unless it meets one of the 12 exemptions. If you take an application at the end of 2017 but final action isn’t taken until 2018, you should capture the new data fields for reporting on the 2018 LAR. You may want to consider, toward the end of 2017, implementing a procedure that would require additional information to be gathered at application in the event that final action is not taken until 2018. If final action is taken prior to 2018, you would simply report the current required fields on the 2017 LAR.
It would be covered under the new rule, but not under the current rule.
So if we collect GMI and it becomes actionable in 2017, are we ok to do so even if it will not be reported under the current purpose test? We do not currently report HELOCs, so if we collected GMI information on it, would we be ok if we collected the info even if it is actioned in 2017.This will help determine if we can hit the switch prior to 01/01/2018.
Yes, if application is taken in 2017 and final action is taken in 2017, you can collect under the current “aggregate” rules or you can collect under the new “disaggregate” rules. If action is taken in 2017 you only report the aggregate categories.
If application is taken in 2017 and final action is taken in 2018, you can collect under the current “aggregate” rules or the new “disaggregate” rules but are still in compliance if you report based on the requirements in effect at the time of collection, rather than the time of final action. This exception in the commentary to the regulation in 1003.4(a)(10)(i)-2.
In summary, it is acceptable to start collecting in 2017.
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