Email to Order Recording + Free Digital Download!
On October 15, 2015, the CFPB released a final HMDA rule to update the reporting requirements of Regulation C. The 797-page rule will make sweeping changes to Regulation C and dramatically expand HMDA reporting and compliance obligations. How will your financial institution handle the 110 data elements in the new rule? There are potential fair lending implications – more data means more analysis to identify potential discriminatory lending practices. The new coverage will include closed-end mortgage loans and open-end lines of credit secured by a dwelling. There will be required reporting of 53 new data fields. In addition, the new rule will require larger HMDA reporters to report data quarterly, rather than annually.
What are the impacts and important changes? Part 1 of this two-part series will address the road map for successful implementation for these sweeping changes. You’ll learn practical tips for developing a strategy that will help you work smarter during 2017 and be prepared when the data collection begins January 1, 2018.
HIGHLIGHTS
What will the rules change?
More types of loans will be covered; the purpose test will be eliminated and the new rule will cover nearly all dwelling-secured loans
Data reporting will be dramatically increased in these categories:
Borrower Information and Underwriting Characteristics (age, credit score, debt-to-income ratio, combined loan-to-value, application channel, and automated underwriting system)
Property Data (postal address and location; property value, number of dwelling units, construction method, manufactured housing information, and multi-family housing information)
Product Features (points and fees, borrower-paid origination charges, discount points, non-discounted interest rate, interest rate, loan term, non-amortizing features, prepayment penalty, qualified mortgage, first draw information)
Identifiers (Universal Loan Identifier and Mortgage Loan Originator Identifier)
Clarification and Revisions to Existing Data Points include reporting the reasons for denial, occupancy type, lien priority, rate spread, HOEPA status, loan type, and loan amount
How is the commercial loan area affected?
How will you handle HELOC reporting?
Impact to the application process due to changes in the collection of government-monitoring information
Review of the HMDA resources provided by the CFPB
TAKE-AWAY TOOLKIT
HMDA key dates timeline and coverage charts
HMDA worksheets and flowchart
Road map template for an implementation plan
Employee training log
Quiz you can administer to measure staff learning and a separate answer key
DON’T MISS PART 2!
This program is the first of two in a series. Watch for “HMDA Roadmap Part 2: Operations Systems, Audit & Reporting Implications” on Wednesday, October 5, 2016.
Attendance verification for CE credits provided upon request.
WHO SHOULD ATTEND? Lenders, personal bankers, loan assistants and processors, loan operations staff, compliance officers, fair lending officers, and auditors.
ABOUT THE PRESENTER – Susan Costonis, Compliance Consulting and Training for FIs, is a compliance consultant and trainer who began her career in 1978. She specializes in compliance management along with deposit and lending regulatory training. Susan has successfully managed compliance programs and exams for institutions that ranged from a community bank to large multi-state bank holding companies. She has been a compliance officer for institutions supervised by the OCC, FDIC, and Federal Reserve. Susan has been a Certified Regulatory Compliance Manager since 1998, completed the ABA Graduate Compliance School, and graduated from the University of Akron and the Graduate Banking School of the University of Colorado. She regularly presents to financial institution audiences in several states and “translates” complex regulations into simple concepts by using humor and real life examples.
No comments:
Post a Comment