Email to order the Recording + Free Digital Download
Only five of the current HMDA fields will remain unchanged – dozens will be added!
The CFPB’s final HMDA rule made sweeping rules changes that become effective in 2018. Why worry now? All dwelling-secured, consumer-purpose loan applications, both closed and open end, will be reported with final action dates after January 1, 2018. Dwelling-secured, business-purpose loans will continue to be reported if they are for acquisition, improvement, or refinance, but business-purpose, open-end lines for those purposes will also be reported. This is a significant change to commercial lending – along with the expanded fields. Regulators are allowing a long implementation window because the changes are complex and will require extensive processing and system changes.
Part 2 of this two-part series will provide a road map for operations, data systems, and audit scope, including the implications of reporting dozens of new data fields. Only five of the current HMDA fields will remain unchanged. More data means more potential errors, increased monitoring/review, and greater fair lending scrutiny. You’ll learn practical tips for developing a strong project plan and working effectively with operations and audit staff as well as vendors that develop software and data-gathering tools.
HIGHLIGHTS
Tips to prepare for five potential surprises in the new rules:
What resources are needed? Key questions about management support, staffing, technology, and impact of operational changes.
What are the key changes in data reporting and analysis? Surprises may include applications that begin in one year but final action occurs in the next year, and potential disconnects when regulators compare different years of data.
What are concerns about operational process decisions? Loan decisions may be made differently for in-house loans than for secondary market loans that use Automated Underwriting Systems (AUS).
Who are the new players? New lines of business will be reported for home equity lines and commercial lending lines for covered purposes. These changes will require revised audit procedures.
What happens next? Expanded data fields will increase fair lending risks and require enhanced analysis. Closer scrutiny by regulators to confirm data integrity will require additional monitoring procedures and resources.
Reporting challenges for the self-identified race and ethnicity fields and tips for operational monitoring
Auditing problem areas such as reporting denial reasons, correct income, property types, and more
Five strategy steps to prepare for the changes:
Highlights of the original rule and hot buttons in operations, audit, and reporting
Current technology review
Compare current data to modified fields and develop a matrix to identify system limitations
Review CFPB resources, like the resources posted on July 18, 2016, that include filing instructions for HMDA data collected in 2018; learn about Filing Instruction Guide (FIG)
Develop a plan for additional training, policy and procedure changes, and project plan assignments
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 THIS RELATED WEBINAR!
“HMDA Roadmap Part 1: Impact, Important Changes & Implementation Considerations for Lenders” Held on Friday, September 9, 2016.
Missed Part 1? Order an archive of the live webinar, complete with handout materials.
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