All in HMDA

HMDA Loan Amount For Counteroffers

Adam Witmer
HMDA

The new HMDA rules have created a whirlwind of challenges for HMDA reporters as reporters have had to learn which knowledge they could retain from the prior rules and which knowledge they had to adjust - not to mention the new elements that had to be learned.  The reality is that it takes time to get all of the “kinks out” when learning a new, especially one that is as complicated as HMDA and Regulation C. A prime example of the challenges that are created due to the implementation of a new rule is the HMDA loan amount when there has been a counteroffer.

CFPB Releases HMDA Filing Instruction Guide for 2019

Adam Witmer
HMDA, Regulatory Update

On October 23, 2018, the CFPB released the Filing Instruction Guide (FIG) for data collected in 2019.  This guide comes less than two months after the most recent version of the guide (August 2018), but is designed to be used for data collected during 2019.  The FIG is considered to be a “technical resource to help financial institutions file HMDA data collected in 2019 and reported in 2020.”

HMDA Refinance vs Cash Out Refinance

Adam Witmer
HMDA

One of the biggest challenges that came with the January 1, 2018 HMDA changes relates to the difference between a refinance and a cash-out refinance.  On the surface, it would not seem to be that difficult but the specifics can actually get quite complicated. Therefore, it is imperative that each HMDA reporter fully understand the difference between a cash out refinance and a refinance.

HMDA Partial Exemption Resources

HMDA Partial Exemption Resources

Adam Witmer
HMDA

In this atypical Compliance Clip (video), Adam explains why those who qualify for the HMDA partial exemption will probably want to use it as quickly as possible. He also manages to relate one of his most embarrassing stories to HMDA.

Reporting the HMDA Purpose for an Interest Buyout

Adam Witmer
HMDA

For years, HMDA has caused all kinds of headaches.  In fact, the acronym “HMDA” itself could just as easily stand for Head Migraine Day Again.  The reason for this, of course, is that HMDA is an infinitely detailed rule, but the rules don’t address every situation which often leaves those responsible stuck between a rock and a hard place, which I commonly refer to as the “gray area” of HMDA.  One area that seems to be in this category relates to how an interest buyout should be reported for HMDA purposes. This article attempts to break down the HMDA purpose reporting requirements for “interest buyout” loans.

Demographic Information for HMDA & Regulation B

Demographic Information for HMDA & Regulation B

Adam Witmer
HMDA, Regulation B

What's the difference between government monitoring information and demographic information? This Compliance Clip (video) explains the differences in information collection under Regulation B and HMDA while also explaining when a bank must comply with one rule or the other for collecting information. In an attempt to make things easier to understand, Adam provides a number of common exemptions for collecting the GMI/DI information.

Predictions on How HMDA for Small Reporters Will Work

Adam Witmer
HMDA, Regulatory Update

It’s never a good idea to “guess” how a new law will be incorporated into a regulation, but I have received quite a few questions regarding how small HMDA reporters will report HMDA data once the CFPB finalizes the changes required by the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018.  Therefore, I want to share my understanding of what I think is going to happen, though you should know full well that this is (mostly) just speculation until changes to Regulation C become final.

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