With continued problems in the mortgage markets, some HMDA-reporting institutions may be required to repurchase loans from an investor because of defaults or may have the opportunity to acquire loans in bulk from another institution. When a loan is repurchased by the originator within the same calendar year as originated, the originator should not report it as sold, and the purchaser (that subsequently puts it back to the originator) should not report it as purchased. […]
Category: HMDA
IMPROVED HMDA REPORTING
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,” […]
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 […]