We’re now a couple years into the “new age” of HMDA – increased coverage requirements, data collection and submission, as well as risk. How are you doing with all this? The CFPB is not yet done in amending the rule; they have a couple proposals outstanding around reporting thresholds and the data elements. But for 2019’s submission season, it’s the same as 2018. But that also means we’re beyond the “good faith efforts to comply” stage of data integrity expectations from the agencies. We’ll review all the pain points of HMDA, including for action taken and various of the data points. We’ll also address a number of questions: What will examiners be looking at it? What are the fair lending issues and risks you need to be aware of after submission? 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 proposals around thresholds and data elements
- CFPB’s rule on private vs. public data
- Details of the coverage rules – who collects and submits information, and when
- What types of loans are reportable
- The dwelling-secured loan standard – what does this impact?
- Changes in the commercial loan area
- How to handle HELOCs
- LAR fields – many additional data requirements
- 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
Who Should Attend?
Loan officers, managers, and processors, compliance and fair lending officers, auditors, counsel, and anyone else with HMDA-related responsibilities, including data collection, reporting, analysis, and disclosure.
Carl Pry is a Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) who is a Managing Director for Treliant Risk Advisors in Washington, DC. Through his working career, as well as through his experience as a banking attorney and officer, he has provided a variety of regulatory compliance and financial performance services to financial institutions and other clients throughout the country. He has written extensively regarding consumer and commercial compliance, tax, audit, and financial institution legal issues, and is a frequent contributor to and currently serves on the Editorial Advisory Board for the ABA Bank Compliance magazine. He has spoken at scores of banking, compliance, and state bar associations, and has conducted training sessions for financial institutions across the country.
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