WHAT?

The 2018 modifications to HMDA were massive and many financial institutions are still dealing with the challenges of collecting data under the burdensome new requirements.  The partial exemption provisions resulting from EGRRCPA were a blessing and a curse. Now with a key exemption being revoked by the CFPB in December of 2022. Knowing what to do and how to do it has never been more important.

Recent activity includes:

• An advanced notice of proposed rulemaking (ANPR) was published on May 8, 2019.The ANPR solicited comments about the costs and benefits of collecting and reporting the data points the 2015 HMDA Rule added to Regulation C and certain preexisting data points that the 2015 HMDA Rule revised. Comments on the APRN were accepted until July 8, 2019.  This rule is still pending.
• On April 16, 2020 the Consumer Financial Protection Bureau (CFPB) published a final rule amending Regulation C to set the thresholds for reporting data about:

1. Closed-end mortgage loans, so that institutions originating fewer than 100 closed-end mortgage loans in either of the two preceding calendar years will not have to report such data effective July 1, 2020. 
2. Open-end lines of credit at 200 open-end lines of credit effective January 1, 2022, upon the expiration of the current temporary threshold of 500 open-end lines of credit.

• On December 7, 2022, the CFPB issued a Notice rescinding its 2020, Home Mortgage Disclosure Act (HMDA) Final Rule changing the loan volume reporting threshold for closed-end mortgage loans.  This comes on the heels of a ruling by the United States District Court for the District of Columbia, in September of this year.  The ruling stated the CFPB did not have the authority to change the original reporting threshold from 25 to 100.

This program reviews data collection and reporting rules, common problems that occur when collecting and reporting the HMDA data, and issues related to the public disclosure of the information.  

WHY?

This two-hour webinar provides insight into the murky areas of HMDA which may result in the failure to report the appropriate loans on the LAR or errors in reported data fields. Participants receive a detailed manual that serves as a handbook long after the program is completed.

PROGRAM CONTENT

The program explores:

The program provides:

• A thorough explanation of which institutions are covered by HMDA and Regulation C for the 2022 reporting cycle;
• Which institutions are eligible for the EGRRCPA partial HMDA exemption and options for compliance available to those institutions.
• A review of which loans are and are not reportable.
• Detailed information on how to complete the LAR.
• Clarification of the rules related to secondary market and broker transactions.
• Detail on the data submission and public availability requirements.
• Steps to identify and eliminate reporting errors and thereby avoid penalties; and
• Actions to take to prepare for submitting the 2021 data to the CFPB.

WHO?

The program is designed for loan officers, compliance officers, loan processors and clerks and auditors.  Whether new to the requirements of HMDA and Regulation C or a seasoned veteran, this program provides a comprehensive review of the existing requirements of HMDA and Regulation C.