What has Changed and What’s Stayed the Same?
The CFPB’s new 2018 HMDA rules are now in effect, although both the OCC CFPB have announced that enforcement of the new rules will be delayed at least a year. What exactly does this mean? As well, the Dodd-Frank reform bill recently signed into law (S. 2155) makes some important changes to the rules, especially for small reporters. Will this have an impact on your reporting for 2018?
The new rules expand what types of loans are covered, and many more data elements are now to be collected. There are also some important changes to definitions and some new clarifications and exceptions, several of which are flying below the radar. As well, the submission and disclosure processes will change, to the new CFPB online method. What do the CFPB’s announcements mean? Short story is don’t change your processes just yet, but there are some things to keep in mind. As well, the existing HMDA data elements must still be collected and submitted properly. We’ll discuss the current state of HMDA in this session, as well as what to look forward to in the future, and get some of your questions answered.
- S. 2155 changes to HMDA – impact to small reporters
- The OCC’s and CFPB’s announcements about the new HMDA rule and delays in enforcement – what does all this mean and what should we do?
- 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?
- New clarifications and definitions
- 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 (new subcategories)
- 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.
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