Top 15 HMDA Issues

This program provides the top 15 issues that may be undermining your HMDA compliance efforts.

The 2018 modifications to HMDA were massive and many financial institutions are still dealing with the challenges of collecting data under the burdensome new requirements.  The partial exemption provisions resulting from EGRRCPA were a blessing and a curse.

Other recent activity includes:

• An advanced notice of proposed rulemaking (ANPR) was published on May 8, 2019.The ANPR solicited comments about the costs and benefits of collecting and reporting the data points the 2015 HMDA Rule added to Regulation C and certain preexisting data points that the 2015 HMDA Rule revised. Comments on the APRN were accepted until July 8, 2019. This rule is still pending.
• On April 16, 2020 the Consumer Financial Protection Bureau (CFPB) published a final rule amending Regulation C to set the thresholds for reporting data about:
  • Closed-end mortgage loans, so that institutions originating fewer than 100 closed-end mortgage loans in either of the two preceding calendar years will not have to report such data effective July 1, 2020.
  • Open-end lines of credit at 200 open-end lines of credit effective January 1, 2022, upon the expiration of the current temporary threshold of 500 open-end lines of credit.
• On December 6, 2022, the CFPB rescinded the small filer exemption for institutions with >100 closed in mortgage loans as a result of a lawsuit filed in the District Court of Columbia stating the CFPB did not have the right to change the law. Starting January 1, 2023, reporting thresholds changed back to <25 closed in mortgage loans for reporting.

WHY YOU SHOULD ATTEND

This two-hour webinar provides insight into the murky areas of HMDA which may result in the failure to report the appropriate loans on the LAR or errors in reported data fields. Participants receive a detailed manual that serves as a handbook long after the program is completed.

This program explores:

1. Which institutions are covered by HMDA and Regulation C;
2. Challenges in determining if a structure is considered a dwelling, such as a manufactured home versus a mobile home;
3. When a mixed-use property is reported as a dwelling;
4. How to report multifamily residential structures, such as manufactured home communities;
5. Clarification on reporting home improvement loans;
6. HMDA reporting requirements for construction and permanent financing versus TRID requirements;
7. The expanded clarification on temporary financing;
8. Whether a financial institution can exempt closed-end mortgage loans and open-end lines of credit now and in the future;
9. The purpose of the Legal Entity Identifier and its impact on the Universal Loan Identifier;
10. Proper reporting of property-related fields;
11. Detailed requirements related to the collection of ethnicity, race, and sex of applicants and borrowers;
12. Challenges with reporting the interest rate and rate spread;
13. Where to locate specific fees from the Loan Estimate and Closing Disclosure required to be reported on the HMDA LAR;
14. When and how to report the use of an Automated Underwriting System; and
15. The partial exemption contained in the Economic Growth, Regulatory Relief and Consumer Protection Act.

WHO SHOULD ATTEND

The program is designed for loan officers, compliance officers, loan processors and clerks and auditors.

All webinar registrations include a recording of the session that can be reviewed as needed.