The CFPB’s new 2018 HMDA rules are now in effect, although the CFPB had announced that enforcement of the new rules will be delayed at least a year. As well, the CFPB recently issued a new proposal on threshold amounts and an ANPR on the new data elements. What will happen here? Will HMDA change yet again? The new rules expanded what types of loans are covered (to include lines of credit), and many more data elements (110, depending on how you count) are now collected. As well, the submission and disclosure processes changed, to the new CFPB online method. What do the CFPB’s announcements mean? What will HMDA data integrity enforcement be like? Should smaller lenders continue to collect the new data if they stopped? Will examiners be looking at it? What are the fair lending issues and risks you need to be aware of after submission? As well, the existing HMDA data elements must still be collected and submitted properly. We’ll discuss the current state of HMDA and get your questions answered.
- Recent proposal on threshold amounts and the ANPR on the new data elements – what may change? What CAN change?
- The CFPB’s announcements about the new HMDA rule and delays in enforcement – what does all this mean and what should we do?
- CFPB’s guidance on private vs. public data
- Details of the new coverage rules – who collects and submits information, and when
- What types of loans and lines of credit are reportable now
- The new dwelling-secured loan standard – what does this impact?
- Changes in the commercial loan area
- 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
- 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
- What to do now that the 2018 data is out there? What types of fair lending analyses should you be doing?
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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