Compliance Action, Volume 22, Number 12/13

*** NEW Feature: Delivering content as it is written ***

To get information to you as quickly as possible, we will post new content as soon as it is available (generally several times per week). The Table of Contents (below) will build as more information is added to each issue. This way, you will be certain to get compliance information in the fastest, most efficient way possible. When an issue is complete, a pdf of the complete issue will be available for download and you will receive an email notification. - Patti Blenden, Editor

HMDA Plus: The Powerful New Narrative (6 Action Steps)

by Patti Blenden

With all of the detail required as of January 1, 2018, it is critical for each bank to know its own story! We have some suggestions for important points you need to think about before you start collecting your data.

HMDA Temporary Financing (§1003.3(c)(3))(Chart)

by Patti Blenden

Dwelling-secured temporary financing loans are now excluded from HMDA reporting, but short-term financing that functions as permanent financing is reportable. It may seem a little confusing, so we've provided some examples for clarification of what is and what is not HMDA-reportable.

Compliance Notes

• CFPB Data Aggregation Principles
• FinCEN Disaster-Relief Advisory

In the Editor's Opinion
An Attitude of Gratitude

by Patti Blenden

Take a little time to appreciate the positives as we continue to face a never-ending cycle of change in compliance. Help your board and management team understand that compliance is an investment in your bank’s ability to accomplish its strategic goals.

HMDA Universal Loan Identifier (Chart)

by Patti Blenden

HMDA's new Universal Loan Identifier (ULI) is a key part of the enhanced life-of-loan accountability. To help you ascertain when a new ULI should be assigned and reported, we've charted some sample scenarios to use as guidelines.

HMDA Application Date (Chart)

by Patti Blenden

When there are multiple versions of an application in commercial dwelling-secured loan files, identifying the Application Date for HMDA reporting can be difficult. New rule requirements for HMDA-reportable commercial loans provide FIs with more flexibility to accurately report application date for commercial loans.

HMDA for Non-HMDA Reporters (2 Action Steps)

by Patti Blenden

To prepare for your next fair lending examination, we suggest Non-HMDA financial institutions implement a more formalized process to track dwelling-secured lending. The word on the street is that examiners are encouraging banks to create their own internal loan application register (LAR) if the bank is not HMDA-reportable to facilitate a fair lending evaluation. We’ve got some suggestions to help you implement a streamlined tracking system.

HMDA Public Data Disclosure (2 Action Steps)

by Patti Blenden

It would be easy with so much focus on the new detailed HMDA data collection process to overlook some of the more mundane procedural changes. The new HMDA public disclosure rules are effective in 2018 for data collected in 2017. You’ll need to update your HMDA policy and procedures to comply with the new public data disclosure rules.

Compliance Q & A

• Loan Denial Based on Fraudulent ID
• Contact Language on Periodic Statements