The CFPB’s new 2018 HMDA rules are now in effect, although the CFPB had announced that enforcement of the new rules will be delayed at least a year. Submission is rapidly approaching – are you ready? The new rules expand what types of loans are covered, and many more data elements (110 to be exact) are now to be collected. As well, the submission and disclosure processes will change, to the new CFPB online method. What do the CFPB’s announcements mean? Should smaller lenders collect the new data? Will examiners be looking at it? What are the fair lending issues and risks you need to be aware of after submission? As well, the existing HMDA data elements must still be collected and submitted properly. We’ll discuss the current state of HMDA so close to submission in this session and get some of your questions answered.
- The CFPB’s announcements about the new HMDA rule and delays in enforcement – what does all this mean and what should we do?
- CFPB’s recent rule on private vs. public data
- Details of the new coverage rules – who collects and submits information, and when
- What types of loans are reportable now
- The new dwelling-secured loan standard – what does this impact?
- Changes in the commercial loan area
- How to handle HELOCs
- New LAR fields – moving to 53 fields, but with many additional data requirements
- New categories of reporting, including information on the property, loan type, and loan features; plus identification information
- Changes on how GMI is reported
- Changes to the submission process
- Quarterly reporting for some institutions
- How the public obtains HMDA information changes
- Practical and compliance implications
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