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Are we required to use the new URLA for new HMDA 2018? Our current vendor does not offer the URLA but has a very similar application that has most of the same information as the URLA. I am hearing that they are not planning on offering the new URLA either but will make some revisions to what they are currently using. Is this a problem?
Currently, there is no required date to utilize the new Uniform Residential Loan Application – 1003. When the URLA was originally published in August 2016, the implementation date was 1/1/2018 but financial institutions had the ability to utilize the form as early as 1/1/2017.
Since the URLA was originally published, additional guidance has been released by Fannie Mae that removed the 1/1/2018 effective date from the bottom of the application and replaced it with “Not for Current Use”. A “Demographic Information Addendum” was published that can be utilized by lenders to collect the expanded demographic categories under HMDA while still utilizing the existing URLA dated 7/05(revised 6/09). If utilizing this addendum, the FI should cross out the existing demographic collection area of the existing URLA. The addendum can be used beginning 1/1/2017.
Below are the links to the guidance document and the addendum:
https://www.fanniemae.com/content/news/urla-announcement-november-2016.pdf
https://www.fanniemae.com/content/guide_form/urla-demographic-addendum.pdf
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