All in HMDA

HMDA - Reporting End Loan as Home Improvement

Adam Witmer
HMDA

With the recent changes to the Home Mortgage Disclosure Act (HMDA) which became effective on January 1, 2018, many compliance professionals have had to rethink how they report certain loan situations for HMDA purposes.  Particularly, there have been some logistical challenges in the way certain Home Improvement loans are reported.

2018 HMDA Getting It Right Guide

Adam Witmer
HMDA, Regulatory Update

The FFIEC has finally released an updated HMDA Getting It Right Guide.  The FFIEC release the new guide today, which is the first revision of the guide since 2013.  The new version has been completely revised to reflect the HMDA changes from the 2015 final rule as well as the 2017 amendments that went into effect on January 1, 2018.  

HMDA Mixed Use Property

Adam Witmer
HMDA

he HMDA mixed-use property test has slightly changed with the new 2018 rules.  Some of what we knew before still applies, but there are definitely some new difference.  Specifically, the mixed-use property test is now a two step process where you must first look at the primary use of a property and then make sure the loan does not have a purpose of home improvement.  First, you must determine if...

HMDA Code for Visual Observation

Adam Witmer
HMDA

There has been some question regarding how to report whether or not demographic information was collected based on a visual observation for applications that were not taken face to face.  Specifically, the question relates to the following field for each part of demographic information: “Collected on the Basis of Visual Observation or Surname.”

HMDA Head Scratcher - The New HMDA Hierarchy

Adam Witmer
HMDA

As is the case with new regulations, we are often left scratching our heads as to why a rule is done the way it is.  For those of you that are HMDA reporters, I’m sure you can relate with the 2018 changes that are now upon us.  In particular, one HMDA head scratcher is the new HMDA hierarchy for reporting the loan purpose.   This article explains why the CFPB made the change.

HMDA Enforcement for 2018 Data

Adam Witmer
Regulatory Update, HMDA

On December 21, 2017, the CFPB (as well as the OCC and FDIC) released a statement announcing the Bureau's intentions for enforcement with respect to errors for data collected in 2018 and reported in 2019 under the Home Mortgage Disclosure Act (HMDA).  Per the release, "the Bureau does not intend to...