On July 5, 2018, three of the regulatory agencies issued statements on how the new regulatory reform law (S. 2155) will affect certain HMDA reporters. Each statement is substantially similar and gives an overview of how the Economic Growth, Regulatory Relief, and Consumer Protection Act amends the Home Mortgage Disclosures Act. Each statement was substantially similar and essentially has three parts.

Jun 25
Jun 25 What is an Acceptable HMDA Error Rate?

Adam Witmer

HMDA

Have you ever wondered what is an acceptable HMDA error rate for your financial institution’s HMDA LAR? You know, how many errors can you have before the regulators would make you scrub your data and resubmit your entire LAR? Well, understanding the HMDA resubmission standards is fairly easy now, though that hasn’t always been the case. This in-depth article takes a deep dive into examiner error rate thresholds, which is especially important right now as financial institutions need to ensure that they are effectively complying with the HMDA changes that went into effect during the beginning of 2018.

May 24
May 24 HMDA Relief for Community Banks and Credit Unions

Adam Witmer

HMDA, Regulatory Update

After passing through Congress on Tuesday, President Trump today signed into law S.2155, known as the Economic Growth, Regulatory Relief, and Consumer Protection Act. This banking reform bill, introduced by Idaho Sen. Mike Crapo in November of 2017, does a number of things to undo the burdens placed on smaller financial institutions by the Dodd-Frank Act. One of those things relates to the new fields that were required under the Home Mortgage Disclosure Act (HMDA) beginning on January 1, 2018.

May 2

May 2 HMDA Visual Observation Field

Adam Witmer

HMDA

This HMDA video talks about the visual observation field for the demographic information and discusses what code to use when the applicant was not seen in person.

Apr 16

Apr 16 HMDA Refinance vs. Cash-Out Refinance

Adam Witmer

HMDA

In this HMDA video, Adam explains when to use a "refinance" code vs a "cash-out refinance" code and explains that a cash-out refinance is just a subcategory of a refinance. He also discusses which code to use for business purpose loans.

Apr 11

Apr 11 HMDA Purpose Statement From Applicant

Adam Witmer

HMDA

In this HMDA video, Adam talks about the purpose field and the requirements (or lack thereof) for proving the purpose of the application.

Apr 9

Apr 9 HMDA Other Purpose

Adam Witmer

HMDA

In this HMDA video, Adam discusses the "other purpose" field on the HMDA LAR and explains when to use it as well as when to never use it.

Apr 1

Apr 1 HMDA Loan Purpose Hierarchy

Adam Witmer

HMDA

In this extended Compliance Clip (about 8 minutes), Adam discusses the new purpose hierarchy in this HMDA video and explains why the CFPB changed the long-standing order of which purposes take priority over other purposes. This video dives into the rule, commentary, and preamble to give us a full understanding of the new HMDA hierarchy.

Mar 29

Mar 29 HMDA Loan Purpose Code for Business Purpose Loans

Adam Witmer

HMDA

This HMDA video focuses on the loan purpose code for business purpose loans. Plus, Adam explains that there is one code you will never use for business purpose loans.