Double

The whole situation wouldn't be so stressful if they didn't have the right to charge monetary penalties for little errors.

One of the questions where comments are requested is regarding the methods of counting errors.

Thank you. I will suggest my boss comment on this.

Kathleen...thanks for the link. I'm sorry to say however that i'm still pretty clueless about MISMO and how it relates to the proposed HMDA changes.

I've only skimmed the proposal so far, but it appears MISMO will be the vehicle to create and maintain the unique loan identifiers. I assume it will work something like the MER's Mortgage Identification Number?

Ah...so we won't just be assigning numbers like we do now? Would that mean that portfolio lenders who don't sell on the secondary market would have to 'join' MISMO (and presumably, pay a fee) for no other reason than to get the identifying numbers? That seems......goofy to me.

We average 109 and most of them are rentals - which don't offer much data anyway. I'm for using that commonly used number 500.
Look at it this way (source: 2011 data from Page 5 - http://www.federalreserve.gov/pubs/bulletin/2012/pdf/2011_hmda.pdf). Someone could chime in if they think I am off base. Small (<$250M) lending institutions making fewer than 500 HMDA loans per year totaled 3,478. If each made 499 loans that would total 1,735,522 loans from a total of 7.1 million loans, which is about 24% of the total loan volume.
Do we see huge violations coming from this small asset sized small population? Would the government miss out on removing that data? Other than the fact that most of the land mass would no longer be accounted for (except for cities), I see no harm in exempting small institutions making fewer than 500 HMDA loans.
We must scrape the barrel when trying to do any kind of statistical analysis doing fair lending reviews. It's tough when you have no data.

The standardized uniform numbering process is not in place yet, even for MISMO. There is a group working on a recommendation.

It is really a waste of time to worry about topics you haven't read. You get yourself worked up over nothing.

You have until October to read this and submit comments. Take a deep breath and read it slowly as time permits.

Isn't (8) Action Taken

Yes, but it was not in the section where they list the items to be reported, for some strange reason.

My read is that your commercial loans that are taking a dwelling as security, regardless of purpose is HMDA reportable....is this correct? Will commercial lending processes now need to begin capturing the GMI information?

Yes, as proposed, commercial loans secured in any manner by a residential property will be covered. If a borrower is an individual, GMI will be needed as it is now.

This will have an impact on CRA and is worthy of commenting.

I think another aspect worthy of comment is that by expanding HMDA coverage to any commercial loan secured in any manner by residential property will result in an inflation of "N/A" reportings since the majority of commercial loans are made to business entities, and the GMI, income and most of the expanded fields will be "N/A."

I am getting a bit tired of having to write an "explanation" on the HMDA confirmation FAX as to why more than 80% of the entries on a LAR do not have GMI.

How would you report the LTV on an "Abundance of caution" 3rd TD lien on a business principal's home? More than likely, you aren't getting an appraisal on it, especially if you have an SBA loan where the guaranty from the principal is secured by a lien on the home.


I think someone needs to submit Ira Levin's "This Perfect Day" as part of their comment. At the rate this is going, we are all going to have to scan our bar-code bracelets for anything we want so that the central computer can review and approve the transaction.

(Google - technocratic dystopia)

I am wondering if we will have the same purpose codes? Sometimes property is taken as an abundance of caution.

The same 3 purpose codes remain with one additional, Other.

Abundance of caution has no effect on HMDA, while it does for CRA. For CRA, a lien on residential real estate taken in an abundance of caution allows that loan to still be a small business Type 1 (if the bank is able to sort that out in its data).

I do plan on commenting on the CRA aspect. In order to properly do a CRA exam if this stays as proposed, while I hate to mention another field, those commercial loans need to have an identifier.

Has anyone found out from the regulations.gov website how to pull this up? I was attempting to read comments already made, and I could not find the proposal out on the page the CFPB gave in the proposal.

The proposed rule is scheduled to be published in Friday's issue (8/29) of the Federal Register.

You can't officially comment until it's actually published. ^Reads Regs^ has learned (and I can confirm) that the publication date is to be August 29.

As a SER who participated on the Small Business Reivew Panel for HMDA, please read the SER's comment letters for guidance and I encourage ALL of you to submit similar comment letters. Much of what we recommended did not find its way into the proposal (e.g. I recommended a 250 entry threshold, elimination of business purpose loans and providing data in ranges to eliminate errors and protect privacy, just to name a few).

Feel free to use our letters when you submit your comments.

Hold on everyone, its going to be a very bumpy ride.

Do you have a link where we can access your letters?

Comment letters from SERs can be found in Appendix A of this document. http://files.consumerfinance.gov/f/201407_cfpb_report_hmda_sbrefa.pdf

Just finished the rough draft of my comment letter...11 pages

Wow, would you be willing to let me sneak a peak?