highlights of the sessionttsmedia.ttstrain.com/hmdacml121615.pdf · 2015-12-11 · 12/16/2015 2...

12/16/2015

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S U S A N C O S T O N I S , C . R . C . M .s u s a n c o s t o n i s @ m s n . c o m

C o m p l i a n c e T r a i n i n g & C o n s u l t i n g f o r F i n a n c i a l I n s t i t u t i o n s

Presents

HMDA (Home Mortgage Disclosure Act)What to Know Now & What’s Next?

December 16, 2015

HIGHLIGHTS OF THE SESSION2

TOPICS FOR THIS SESSION

Overview of the HMDA requirements for 2015 activityWho reports HMDA data?What types of loans are covered?What data is reported?When is the data reported? How is the data reported? How to properly report data of the 26 required fieldsCommon reporting mistakes and practical tips for

managing the process

Best practices for HMDA data validation

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Overview of the NEW RULES3

October 15th, 2015 the CFPB released a final HMDA rule to update the reporting requirements of Regulation C.

The final rule does not include several of the data points proposed in 2014 by the Bureau (such as the "risk-adjusted, pre-discounted interest rate"), and does not adopt the proposal to require reporting of all dwelling-secured transactions made for commercial purposes.

Most of the provisions of the final rule will take effect on January 1, 2018. Lenders will collect the new information in 2018 and then report this information by March 1, 2019. High-volume originators will file quarterly beginning in 2020.

HMDA History4

1975: HMDA was enacted by Congress, and was implemented by the Federal Reserve Board’s Regulation C.

1989: Congress expanded HMDA to require financial institutions to report racial characteristics, gender, and income information on applicants and borrowers, among other things.

2002: The Federal Reserve began requiring identification of higher priced mortgage loans, identification of manufactured homes, reporting of denials from pre-approved programs conformed data on ethnicity and race to standards.

2010: Congress amended HMDA in the Dodd-Frank Act, which also transferred HMDA rule-making authority to the CFPB.

2014 – The CFPB announces a proposed rule that contains the Dodd-Frank requirements and many additional reporting changes.

2015 – The CFPB released a final rule on October 15, 2015 that becomes effective January 1, 2018.

IMPACTS? – Increased compliance oversight & fair lending analysis

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Purpose and Coverage5

HMDA applies to a variety of both depository and non-depository institutions including banks, savings and loans, credit unions, and mortgage companies. These institutions are required to report date relating to applications, preapprovals, originations and purchases of:

home purchase loans

home improvement loans and

refinancings

HMDA Flow Chart6

Is the loan secured by and made for purpose of purchasing a dwelling? Is it temporary financing? Are any of the proceeds to be used for home improvement? (secured by

dwelling) Is it a line of credit? Are any of the proceeds to be used for home improvement? (not secured

by dwelling) and is classified as home improvement? Will the new loan secured by a dwelling replace and satisfy an old loan

which is also secured by a dwelling? (Refinance – purpose does NOT matter)

DWELLING means any residential structure regardless of the number of acres, number of units (4-plex or greater), whether or not it is the primary dwelling, second home, rental property. The term dwelling includes condos, mobile home or manufacture home or apartment building. It doesn’t include transitory residences like hotels or dorms.

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HMDA Reporting Basics7

WHO REPORTS HMDA DATA?

FI’s are required to report HMDA data based on asset size, location of a branch in a MSA, and certain coverage criteria; see link

WHEN IS IT REPORTED?

By March 1st for the activity completed in the prior year

HOW IS IT REPORTED? Sent electronically to the FFIEC or by paper

WHAT IS REPORTED? Twenty-six data fields for each covered application

WHAT TYPES OF LOANS ARE REPORTED?

Three types of applications – home purchase, home improvement, refinancing.

WHAT IS OPTIONAL? Reporting denial reason is optional, except for OCC Banks; certain pre-approval codes are optional; home equity line of credit reporting is optional

Who Reports HMDA Data?8

Banks, savings associations, or credit unions that

Exceeds the asset threshold that is adjusted annually

Had an office in an MSA on the preceding December 31st

Meets certain federal criteria, such as being FDIC insured

Adjusted asset-size exemption threshold for 2014 to $43 million

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Important HMDA Definitions9

Dwelling A “dwelling” is a residential structure whether or not it is attached to real property located in the U.S., District of Columbia or Puerto Rico. A dwelling includes:• not only a principal residence but also a vacation

home and rental properties, individual condo units, mobile home or manufactured home and “camps”

• multifamily structures like apartment buildings

A dwelling DOES NOT include RVs and campers or transitory residences like hotels and hospitals, dorms whose occupants have a principal residence elsewhere.


Home purchase loans

A home purchase loan is a loan that is both secured by and made for the purpose of purchasing a dwelling. This includes a loan secured by one dwelling that is used to purchase another dwelling

Mixed-use property

A dwelling-secured loan to purchase property that is primarily used for residential purposes is a home purchase loan. For example, an apartment building could include a convenience store but the primary property use is residential. Any reasonable standard can be used to determine primary use from square footage to income. This can be done on a case-by-case basis.

Farm loans A loan to buy property that is primarily for agricultural purposes is not a home purchase loan, even if it includes a dwelling. Any reasonable standard can be used to determine primary use, like the RESPA exemption of 25 acres or more. This can be done on a case-by-case basis.

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Commercial and other loans

A home purchase loan does not need to be made solely in the mortgage or consumer loan department. The purchase of an apartment building (that is secured by that or any other dwelling) is reported as a home purchase loan.

Construction and permanent financing

A home purchase loan includes a combinedconstruction/permanent loan; it does not include a construction-only loan which is considered temporary financing.

Second Mortgage down payment

If an institution makes a first mortgage to a purchase and a second mortgage loan to the same purchases to finance all or part of the down payment, it reports each loan separately.


Home improvement loans

For HMDA reporting purposes, a home improvement loan is: • A loan secured by a lien on a dwelling that is for

the purpose, in whole or in part, of repairing, rehabilitating, remodeling, or improving a dwelling or the real property on which it is located

• A non-dwelling-secured loan that is for the purpose, in whole or in part, of repairing, rehabilitating, remodeling, or improving a dwelling or the real property on which it is located and that is classified by the financial institution as a home improvement loan.

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Dwelling-secured home improvement loans

Institutions must report under the home improvement loan category any loan OR application for loans secured by a lien on a dwelling if any portion of the loan proceeds would be used to repair, rehabilitate, remodel or improve a dwelling or the real property upon which it is located.

Non-dwelling-secured home improvement loans

Non-dwelling-secured loans and applications that are for the purpose, in whole or in part, of home improvement continue to be reported only if the institution classifies them as a home improvement loan. This could be done by computer coding, color coded files, or the call report.


Improvements to real property

Home improvement include not only improvements to the dwelling itself, but also improvements to the real property upon which the dwelling is located, for example installing a swimming pool, construction of a garage, or landscaping.

Commercial and other loans

A loan to improve an apartment building through the commercial department is a home improvement loan if it’s secured by a dwelling or if unsecured it is classified as a home improvement loan.

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Mixed-use property

A dwelling-secured loan to improve property that is for both residential and commercial use is considered home improvement only of the loan proceeds are used primarily to improve the residential portion of the property. Any reasonable standard can be used to determine primary use from square footage to income. This can be done on a case-by-case basis.

Multiple-category loans

A loan for purchase as well as home improvement or refinancing is reported as HOME PURCHASE. Purchase trumps ALL categories if a loan or application qualifies as a home improvement loans AS WELL AS refinancing, it must be reported as HOME IMPROVEMENT. Home improvement TRUMPS refinance. Remember H before R.


Refinancings A refinancing is a new obligation that satisfies and replaces an existing obligation. If the existing obligation is not satisfied and replaced, not only renewed, modified, extended, or consolidated, the transaction is not a refinancing for HMDA purposes. NOTE: If a new note is prepared and signed for a HMDA reportable renewal, it IS considered a refinancing for HMDA .

Reportable refinancings

Refinancings are reported under HMDA only if both the existing obligation and the new obligation are secured by liens on dwellings. Lenders may rely on the applicant’s statement about whether or not the loan being refinanced is dwelling-secured.The purpose of the loan being refinanced is not relevant to determining if the loan qualifies as a refinance.

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Refinancing FAQs from the FFIEC17

Refinancing – loan purpose. If an obligation satisfies and replaces another obligation, is the purpose of the replaced obligation relevant to whether the new obligation is a reportable "refinancing" under Regulation C?

Answer: No. The new definition of a reportable refinancing looks only to whether (1) an obligation satisfies and replaces another obligation and (2) each obligation is secured by a dwelling. Thus, for example, a satisfaction and replacement of a loan made for a business purpose is a reportable refinancing if both the new loan and the replaced loan are secured by a dwelling.

Refinancing – cash out for home improvement. How should a lender code a dwelling-secured loan when the borrower uses the funds both to pay off an existing dwelling-secured loan and to make improvements to a dwelling?

Answer: A dwelling-secured loan that meets the definitions of both "home improvement loan" and "refinancing" should be coded as a "home improvement loan.”

Temporary Financing FAQs 18

Temporary Financing. When is a loan "temporary financing" such that it is exempt from reporting?

Answer: The regulation lists as examples of temporary financing construction loans and bridge loans. See 203.4(d)(3). Construction and bridge loans are illustrative, not exclusive, examples of temporary financing. The examples indicate that financing is temporary if it is designed to be replaced by permanent financing of a much longer term. A loan is not temporary financing merely because its term is short. For example, a lender may make a loan with a 1-year term to enable an investor to purchase a home, renovate it, and re-sell it before the term expires. Such a loan must be reported as a home purchase loan. See 203.2(h).

THINK **********FIX AND FLIP************

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Government Monitoring Information19

In an application for a HMDA reportable loan, an institution must collect the applicant’s ethnicity, race, and sex as PART of the application process.

This information is not required when the applicant is a legal entity, such as a corporation or partnership, rather than an individual. If the applicant is a sole proprietor YOU MUST STILL COLLECT THE MONITORING INFORMATION. This will mean you also report income of the sole proprietor if it was relied on to make the credit

decision.

Government Monitoring Information20

Consumer loan requests to purchase a principal dwelling or refinance the purchase money should be taken on a FNMA 1003 application.

Other requests (home improvement and non-purchase money refinance requests may be done on a consumer application along with a HMDA data collection form.

The form is found in Appendix B of the Getting it Right Guide

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HMDA Data Collection Form21

Obtaining Government Monitoring Information

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The applicant must be informed that the federal government requests this information in order to monitor compliance with antidiscrimination laws.

The applicant must be informed that if he or she does not provide the information when the application is taken in person, the lender is required to note the date based on visual observation or surname.

Document HOW the application was taken –in person, by mail, by phone, or via the Internet. SEE THE FAQs

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Obtaining Government Monitoring Information

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In person application – always request the information by reading the form; if the applicant refuses to provide it make a visual observation and document accordingly

Telephone applications – always request the information by reading the form; if the applicant refuses to provide it document accordingly

Mailed applications – the monitoring information should be included on the application. If it wasn’t on the application, send a form letter and monitoring information form. If YOU MEET THE APPLICANT PRIOR TO APPROVAL the information must be requested and the “in-person” requirements apply.

ALWAYS DOCUMENT how the application was received.

HMDA Data Exclusions24

There are six exclusions for HMDA reporting in Regulation C. Financial institutions should NOT report the following:

1. Loans originated or purchased by the financial institution acting in a fiduciary capacity (such as trustee)

2. Loans on unimproved land

3. Temporary financing (such as bridge or construction loans)

4. The purchase of an interest in a pool of loans (such as mortgage-participation certificates, mortgage-backed securities, or real estate mortgage investment conduits)

5. The purchase solely of the right to service loans

6. Loans acquired as part of a merger or acquisition, or as part of the acquisition of all of the assets and liabilities of a branch office as defined in Sec. 1003.2.

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How to Tell Whether a Loan is HMDA Reportable

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Purchase a dwelling

Refinance

Home improvement

Construction only

Construction/perm

HMDA LAR Data Fields and Control Methods

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BEST PRACTICES FOR FILE DOCUMENTATION

1. Create a HMDA file folder for each LAR entry that can be verified by a person or team that is knowledgeable in HMDA procedures

2. Label EACH data field in this file with the numbers that correspond to the HMDA LAR (1-26)

3. Highlight each data field on the source document next to the number of the data field.

4. Perform a second review of the data5. Sign-up for the FFIEC e-mail alerts for HMDA; maintain a current copy of the

“HMDA Getting it Right Guide”6. Revised written procedures as needed when changes are made to HMDA or

deficiencies are noted in audits and exams.7. Train new employees; provide refresher training for all lending employees.

Annual training is not required but should be done in accordance with exam and audit findings.

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Best Practices for File Documentation27

DATA FIELD CONTROL METHOD COMMENTS

1. Application or Loan Number

Loan number if originated; unique code number if denied, withdrawn, or approved and not accepted – this may be date of application with a “D”, “W” or “A”.

Do not use Social Security number or other personally identified information

2. Date Received Date indicated on Consumer or Commercial Approval Worksheet for originated loans; date that the application received on denied/withdrawn loan worksheet.

Common error if the applications are not date-stamped or systematically created in loan application software. Often a problem with business purpose loans and there may not be a commercial loan application

3. Loan Type Usually conventional loans Can be a problem if there is a great deal of secondary market activity. Use software to populate this data field if possible


DATA FIELD CONTROL METHOD COMMENTS4. Property Type Real Estate collateral codes.

Property type for denied or withdrawn or approved but not accepted loans on Denied-Withdrawn Worksheet

These are the property types to verify: 1. One to four family (other than

manufactured housing)2. Manufactured housing3. Multi-family

5. Purpose of Loan

Purchase (secured by a dwelling)Home improvement – can be secured or unsecured (purpose driven)Refinance – purpose doesn’t matter, collateral driven

Purchase trumps all, home improvement trumps refinance. construction loan that is being converted to a permanent loan –report as a purchase loan

6. Occupancy Use codes on boarding data if originated; require this information in the application process

Code 2 for second or vacation homes and rental properties. Code 3 multi-family loans, property is not in an MSA, in an MSA without a branch.

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7. Loan Amount Use the amount of the note if originated; use the application amount if denied, withdrawn, or approved but not accepted

Highlight loan amount on note for originated loans, highlight loan amount on application or adverse action notice. Loan amounts are ROUNDED to the nearest $1,000; example: a loan for $167,300 would be 167 and $15,500 would be 16.

8. Pre approval Code

Always 3 if there is no pre-approval program.

Can be a high error field when beginning a pre-approval program



9. Action Taken Type

1. Loan originated2. Application approved, not

accepted.3. Application denied 4. Application withdrawn by

applicant5. File closed for

incompleteness6. Loan purchased by

financial institution7. Preapproval request

denied by financial institution

8. Preapproval request approved by not accepted (optional reporting)

1. Have copy of the note in file2. Documentation must be clear.3. Copy of adverse action notice4. Document date of withdrawal, only

use if it was withdrawn by applicant prior to credit decision

5. Copy of adverse action notice6. Copy of purchase info in file. 7. Documentation should be clear and

copy of letter.8. Documentation should be clear and

support the preapproval program guidelines.

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10.Action Taken Date Date of loan if originated, denial date, withdrawal date, date that customer declined loan approval

Copy of note, highlight date; copy of denial; file documentation of withdrawal notice or note to file that customer did not accept approval.

11.MSA/MD FFIEC website Make sure you have geo-coded the correct property and used the CORRECT geo-code year; don’t use appraisal or flood determination information unless verified to FFIEC

12.State FFIEC website

13.County (Parish) FFIEC website

14.Census Tract FFIEC website



15.Ethnicity (Applicant) Request for in-person applications (must make visual observation or surname if the applicant declines to provide it) Read during phone applications; request for mailed applications

If the borrower is not a natural person (corporation or partnership) use the code for “not applicable”. The FDIC requires monitoring info for a sole proprietor.

16.Ethnicity (Co-Applicant)

If there is more than one co-applicant, provide monitoring info for the first co-applicant listed.

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17. Race (Applicant) Applicants can select more than one race, enter all codes they designate

18. Race (Co-Applicant) If there is more than one co-applicant, provide monitoring info for the first co-applicant listed.



19.Sex (Applicant) If the borrower is not a natural person (corporation or partnership) use the code for “not applicable” The FDIC requires monitoring info for a sole proprietor.

20.Sex (Co-Applicant) If there is more than one co-applicant, provide monitoring info for the first co-applicant listed.

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21. Income The gross income your institution used to make the credit decision.

Round to the nearest thousand. Report $35,500 as 36. If the borrower is not a natural person (corporation or partnership) use the code for “not applicable”. Loans for multi-family should use NA for income.

22. Purchase Type See codes in the Guide Enter the code sold to the secondary market within the same calendar year

23. Reasons for denial Optional; see codes REQUIRED for OCC banks


DATA FIELD CONTROL METHOD COMMENTS24. Rate Spread Report for purchase, refinancing,

or dwelling secured home improvement loans that are made for a consumer purpose that are originated. CRITICAL to document the date the interest rate was set for the final time before closing.

Do NOT report rate spreads for loans that aren’t subject to Reg Z or unsecured home improvement loans. The format is 03.29 (leading zero and two decimal places; rounded if more than two decimals). Make sure that the lien status is accurate.

25. HOEPA status Report as code 1 for loans subject to HOEPA that were originated

26. Lien Status Use the collateral codes on the boarding data as documentation

The accuracy of lien status is critical for determining rate spreads correctly.

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List of HMDA Problems and Solutions37

1. Failure to include loan applications that resulted in denial or withdrawal. Solution: Develop and follow sound HMDA reporting procedures. REMEMBER: If a NEW note was prepared, it is a possible HMDA refinance transaction.

2. Failure to include applications for mobile homes or multifamily dwellings originated as part of the consumer or commercial loan portfolio.

3. Reporting temporary construction loans. Solution: Follow written procedures for the definition used by your bank for “temporary” loans. REMINDER: FIX & FLIP LOANS ARE PURCHASE TRANSACTIONS!


4. Reporting multi-purpose loans – If a loan is a home purchase loan as well as a home improvement loan, or a refinancing, an institution reports the loan as a home purchase loan. If a loan is a home improvement loan as well as a refinancing, an institution reports the loan as a home improvement loan. Purchase trumps all. Home improvement trumps refinance. SOLUTION: Remember the codes: 1 = Purchase; 2 = home improvement; 3 = refinance !!!!!

5. Second mortgages that finance the down payments on first mortgages – if an institution making a first mortgage loan to a home buyer also makes a second mortgage loan to the same purchases to finance part or all the home purchaser’s down payment, the institution reports each loan separately as a home purchase loan. SOLUTION: Code these types of loans correctly and follow written HMDA procedures.

6. Which income should be used? The gross annual income is the income that your institution relied upon in making the final credit decision. SOLUTION: Be consistent is reporting this information!

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7. Income must be rounded to the nearest thousand. SOLUTION: Take the time to record this correctly.

8. Dwelling is NOT limited to the principal or other residence of the borrower and includes vacation or second homes and rental properties. SOLUTION: Be cautious with any loan request that involves the purchase, improvement or refinance of a dwelling.

9. Property location – Multiple properties – For a home improvement loan, an institution reports the property being improved. If more than one property is being improved, the institution reports the location of one of the properties (more common method) or reports the loan using multiple entries on the LAR (with unique identifiers) and allocating the loan amount among the properties. SOLUTION: Follow your bank’s written procedures.


10. Multiple properties – For a home purchase loan, an institution reports the property taken as security. If an institution takes more than one property as security, the institution reports the property being purchased if there is just one. If the loan is to purchase multiple properties and is secured by multiple properties, the institution reports the location of one of the properties (more common method) or reports the loan using multiple entries. SOLUTION: Follow your bank’s written procedures.

11. Mixed-use property – A loan to improve property used for residential and commercial purposes (for example, a building containing apartment units and retail space ) is a home improvement loan if the loan proceeds are used primarily to improve the residential portion of the property. If the loan proceeds are used to improve the entire property (for example, to replace the heating system) the loan is a home improvement loan if the property itself if primarily residential. An institution may use any reasonable standard to determine the primary use of the property, such as by square footage for by the income generated. An institution may select the standard to apply on a case-by-case basis. SOLUTION: Follow your bank’s written procedures.

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12. Failure to collect monitoring data (ethnicity and race). SOLUTION: follow your bank’s procedures. Remember that you are required to READ the data collection information to phone applicants and request it from in-person applicants. Appropriate forms should be included with applications sent by mail to applicants. It is critical that you document HOW an application was taken – in-person; by phone; by mail.

13. Rate-spread calculations – this is a 2 decimal point field and should be rounded and reported as 7.29% if the calculation was 7.286%


14. Correct purchase codes. This question was sent prior to the presentation: “What is the correct code for a loan that is sold to the Federal Home Loan Bank? For many years the bank reported these loans as a code 6 (commercial bank). The regulator questioned this code during the last exam and said they should be coded as a 9. A message was sent to the HMDA Help Desk AND directly to a regulator. Both confirmed that the correct code should be a “9” for “Other type of purchaser.” When asked about the number of years that might have to be submitted, the HMDA Desk said that the regulator is the final authority but they will only accept the last two years of reporting.

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Common HMDA Problems Found in Independent Audits

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1. Lack of written procedures for entire HMDA process.

2. Lack of effective "scrub" processes – this should be done at least quarterly. The individual who has collected the initial information and completed the input should NOT be the person to perform the scrub. The person doing the scrub should be knowledgeable about HMDA requirements and not be involved in the collection and input process. All LAR entries should be completed within 30 calendar days after quarter-end for qualifying applications.

3. HMDA reportable loans found on loan trial or in adverse loan files but not on LAR. The regulators request a loan trial and sort by loan date and collateral to identify potential loans that should be on LAR. Ideally, the monthly “new loan report” and applicable adverse action, withdrawn, and approved but not accepted files should be compared EACH month to the LAR.


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4. There is often confusion between "short term" and "temporary" financing. Banks have failed to report the "fix and flip" loans. See “Temporary Financing” Flowchart in the Supplement.

Another example would be a 6-month loan for dwelling renovations where repayment coming for insurance proceeds or bonus money. The loan is reportable – it is short-term but not "temporary financing."

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Third example – Borrower had bought a property at sheriff sale with their money. The applicant then requests a loan to reimburse himself. The loan is secured by the purchased property. The loan is NOT HMDA reportable as it is not a purchase, refinance, or home improvement.

Fourth example – Borrower made a construction/perm loan at the bank to build personal residence. Construction costs exceed loan amount. Borrower requests additional funds to complete residence to be secured by a CD. The CD secured loan is not HMDA reportable as it is not purchase, refinance or home improvement.

SEE FDIC SUGGESTIONS for

Ensuring completeness

Ensuring Accuracy


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5. There is often a problem with relying on “automation” to complete the LAR. This may happen when a bank uses a mortgage underwriting system to capture the information. If there are inconsistencies with the data fields, there will be errors in the LAR. (aka…garbage in, garbage out)

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HMDA Changes Proposed47

1. Rule of 25

2. Types of transactions

3. Align data requirements

4. New data points reported

Information about applicants

Information about property

Loan features

Certain unique identifiers5. Modifications to disclosure and reporting requirements

6. Clarify the regulation

CFPB Goals in the HMDA Proposal48

Better information about the mortgage market Monitoring access to credit Standardize the reporting threshold Ease reporting requirements for some small banks Aligning reporting requirements with industry

data standards Improving the electronic reporting process Improving data access

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Specific Data Fields49

1. Information about applicants, borrowers, and the underwritingprocess, such as age, credit score, debt-to-income ratio, reasons fordenial if the application was denied, the application channel, andautomated underwriting system results.

2. Information about the property securing the loan, such as constructionmethod, property value, lien priority, the number of individualdwelling units in the property, and additional information aboutmanufactured and multifamily housing.

3. Information about the features of the loan, such as additional pricinginformation, loan term, interest rate, introductory rate period, non-amortizing features, and the type of loan.

4. Certain unique identifiers, such as a universal loan identifier, propertyaddress, loan originator identifier, and a legal entity identifier for thefinancial institution

EFFECTIVE DATE: January 1, 2018; see HMDA RULE KEY DATES

EXECUTIVE SUMMARY OF THE 2018 HMDA RULERule Changes

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Transactional Coverage

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Reportable Data

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Collection & Reporting of Applicant Information

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Collection & Reporting of Applicant Information

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Data Submission

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New web-based submission in 2018

Electronic submission required

Effective January 1, 2019 Appendix A is removed

Tools available, see link

Quarterly reporting – 2020 based on threshold of 60,000 applications in preceding calendar year; begins May 30, 2020.

Disclosure Requirements56

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SUMMARY OF THE CHANGES57


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Summary of Reportable Data61


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Key Dates Timeline66

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HMDA Data Analysis 67

STEPS IN HMDA DATA ANALYSIS – THE FUNDAMENTALS

1. Compare apples to apples; segment products based on the eight types of loan products used by regulators in HMDA analysis

2. Compare apples to apples; compare the loan pricing within each product between target groups to detect potential discrimination

3. Ensure the accuracy of data to be reviewed

4. Look for potential redlining in your assessment areas and any conspicuous gaps to serve target groups

HMDA Questions and Quick References68

[email protected] – E-mail is the preferred method of correspondence with HMDA operations staff to resolve issues about HMDA.

[email protected] – This address is used for submitting the HMDA Internet e-mail submissions only. No other correspondence should be sent to this address.

During January through May, the busiest part of a year for HMDA data collection and processing, [email protected] an increased volume of inquiries. Please understand the response time could exceed 2 business days.

We highly recommend you utilize the resources listed below prior to your "help" inquiry to assist with HMDA processing and reporting questions.

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A Guide to HMDA Reporting: Getting It Right!

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The 2013 version of the HMDA GETTING IT RIGHT GUIDE can be found on the FFIEC website. This is the link: http://www.ffiec.gov/hmda/guide.htm

There is a 2015 Informational Guide Letter to supplement the Guide

Any questions or requests for additional information should be directed to: Assistance Line: (202) 452-2016; Internet E-Mail Address: [email protected]

SUGGESTIONS:

1. Print the GUIDE and highlight sections that contain common problems or helpful guidance. The GUIDE is 119 pages. Appendix A has instructions for completing the LAR. Appendix D has the official staff commentary to HMDA and can be very helpful to understand the reporting requirements.

2. SAVE a copy of the PDF on the computers of HMDA review employees. Use the “FIND” function of Adobe to search for key words to locate ALL the references to a given topic like “applicant” or “purpose code,” etc.

3. Keep copies of any E-mail responses to inquiries received from the HMDA Help Desk

FFIEC HMDA Page70

Sign-up for E-Mail Alerts

What’s New?

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HMDA Toolkit71

Questions!!!72

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Thank You!

Susan [email protected]

Kyle [email protected]

Upcoming Webinars

• December 16th – Developments in Federal Wage and Hour Law

• December 17th – IRS Information Reporting: What You Need to Know About the Rules and Forms

• December 17th – Compliance Perspectives

• December 18th – BSA Year End Wrap Up

• January 7th – Lending to Municipalities

• January 12th – Writing High Quality Email

• January 12th – IRA Update and Review

• January 13th – Understanding CCC Loans for Ag Lenders

• January 14th – Currency Transaction Reporting: Line by Line

• January 20th – Business Resolutions and Authorizations: Use Them to Protect Your Financial Institution

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HMDA – NOW & WHAT’S NEXT?

highlights of the sessionttsmedia.ttstrain.com/hmdacml121615.pdf · 2015-12-11 · 12/16/2015 2...

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