Many of you are in the throes of scrubbing your Home Mortgage Disclosure Act (HMDA) data. Following are a few thoughts that might help improve your HMDA reporting. Many HMDA-reporters misreport data in the “Action Taken” and “Gross Annual Income” fields of the Loan Application Register (LAR). Commons errors involve: Using the wrong Action Taken code when the loan application has been identified as “a preapproval request that did not transition to a loan application,” […]
Category: HMDA
RESUBMITTING HMDA DATA
Right now HMDA reporting banks across the nation are checking, double-checking, scrubbing and reviewing their HMDA data. Some will find errors. Correcting errors before the data has been submitted to your regulator is a fairly easy task. But when examiners, auditors or others find errors in data previously submitted to regulators how do you correct those prior year errors? Assume your calendar year 2010 HMDA data was submitted on schedule by March 1, 2011. During […]
HMDA – REPORTING MULTIFAMILY PROPERTIES
Lenders reporting HMDA data must complete the “Property Type” field on the Loan Application Register (LAR) to identify the type of property. Options include one-to-four family dwelling (other than manufactured housing), manufactured housing, or multifamily dwelling. The “multifamily dwelling” property type is often misreported due to a lack of understanding of the definition of multifamily dwelling. For HMDA reporting, a multifamily dwelling is a residential structure that houses five or more families. Even though condominium […]
THE CFPB INHERITS REGULATION C
The Home Mortgage Disclosure Act requires most mortgage lenders located in metropolitan areas to collect data about their housing-related lending activity. Annually, lenders must report those data to the appropriate Federal agencies and make the data available to the public. Historically, HMDA has been implemented by the Federal Reserve’s Regulation C. In addition to various substantive amendments, the Dodd-Frank Act transferred rulemaking authority for HMDA to the Bureau of Consumer Financial Protection (CFPB), effective July […]
CFPB – THE INHERITED REGULATIONS – PART II
On November 29th the Consumer Financial Protection Bureau (CFPB) published a notice and request for information about streamlining the inherited regulations. The “inherited regulations” include 14 existing consumer regulations that the CFPB inherited from other regulatory agencies on July 21, 2011, including, among others, Regulation Z (Truth in Lending) and Regulation X (RESPA). The inherited regulations are published in Chapter X of Title 12 of the Code of Federal Regulations. Following is the schedule of […]