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Latest Compliance - HMDA Topics

Code for Mortgage if Borrower Decides to Withdraw

03/10/2019

I have a mortgage that has been approved, commitment signed and returned, all conditions have been met by the borrower. Borrower has now decided to withdraw. How do I code this? It is not a withdrawal, not a decline. Would it be approved not accepted?

Rounding When Reporting On LAR (HMDA)

03/10/2019

We have a loan for $3,372,000 that is HMDA reportable and we are going back and forth on how this should be rounded. Do we report 3400 or 3372 on the LAR?

Violations w/Regs B&C and UDAAP? Denial Reasons

02/03/2019

Are there possible compliance violations with Regulations B & C and UDAAP if denial reasons are different on the HMDA LAR than what was on the Notice of Adverse Action? For example: at the time of decline, the denial reason listed on the NOAA was "Other", but when the file was reviewed for HMDA data validation, the true denial reason should've been a Collateral decline.

Renewal w/Vacant Land as Collateral-Evaluation

07/15/2018

Two years ago we granted a new loan and took a first mortgage on a piece of vacant land as collateral. The loan is now going through a renewal. While completing the evaluation, we learned that the borrower; using his own cash, built a home on the property that’s encumbered. The way our mortgage reads, we have interest in ... all existing or subsequently erected or affixed buildings, improvements, and fixtures... When we complete the valuation report, should the value of the home be included in the report and furthermore, if so, should the report be mailed to the borrower under Regulation B?

HMDA Reporting - Brokered Loans on LAR

09/03/2017

I attended a seminar last week and I discovered that our bank, ​which I thought was approving and selling loans, was actually acting as a broker. Upon speaking to the primary loan officer for these loans I found out that we do not do any of the underwriting for these loans, nor do we make the credit decision. The purchaser is putting these loans on their LAR (as they should), but so have we. I have been working here nearly a year now and just found that information out and I am upset with myself for not knowing this information before now. I looked at our LAR from last year and see that nearly half of the loans on the LAR should not have been reported as they were these brokered loans. It is the same story as far back as 2014. Do we need to go back and re-submit the LAR(s) or can we proceed as normal? Are we looking at penalties? I am really shocked at this news. After several exams and outside audits, this was never discovered until now. I would really appreciate any tips you can offer.

Additional Funds Home Improvement-HMDA?

04/23/2017

In 2015 we reported this commercial loan as a Home Improvement loan on the LAR. The loan was commercial non-revolving line of credit for $50,000 that matures on 11/1/2016. On 5/15/2016 the borrower came back for an additional $30,000 to be added to this loan as the improvements are not complete. The additional funds paid off a non-dwelling secured loan, a small advance to the borrower, and the rest remains available on the non-revolving line of credit. None of the new funds satisfied any dwelling secured loans. In most cases when a borrower requests additional funds, we pay off the existing loan and book a new loan for the total of the old loan + the new amount request. Thus, it is always reported for HMDA as a home improvement as loans that are for both refi + home improvement = home improvement. In this case, being this is a commercial loan, the lender did not pay off the existing dwelling secure loan. We just added an additional $30,000 to the line of credit. Because we didn’t “satisfy” any dwelling secured loans, am I correct that this is not reportable for HDMA and is technically considered a Commercial Modification. Is this the correct interpretation of this loan? If any of the additional funds paid off/satisfied another dwelling secured loan, would this be considered HMDA reportable as either a refinance or home improvement loan? If so, is the entire loan amount reportable or just the increase?

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COMPLIANCE Q & A: Reg C, houseboats, and dwellings

Question: I thought that houseboats were not considered “dwellings” for purposes of HMDA reporting.

HMDA & Credit Score Reporting

Question: We have an interesting HMDA dilemma and we would like your opinion, please.

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Most Popular Compliance Content

Reg E Question About Credit Card Fraud

10/25/2020

When a cardholder has a fraud alert on their card and they tell the fraud center that the transactions are NOT fraud, the fraud center reopens the card. Now the customer has roughly 10 or more charges from the same company that she just said were not fraud. Now she is claiming that they are all fraud. (including the original charges) What do we do?

Chamber of Commerce Cash & Prize Giveaway

10/25/2020

Our Chamber of Commerce is hosting a cash & prize giveaway to encourage people to shop local during the holidays. As a member of the Chamber of Commerce, the bank has been asked to pass out tickets as entries to win. Each business has a limited number of tickets. Employees of the bank are not allowed to obtain any tickets from the bank, but can from other businesses participating. My question is, can we offer multiple tickets as incentives for our customers to use other services we offer? Examples would be: 1) A customer comes in to make a deposit= 1 ticket. If they sign up for online banking while here we will offer an additional ticket. 2) A non customer comes in to cash a check= 1 ticket. If they open an account with us we will offer additional tickets. 3) A customer asks about a home loan= 1 ticket. If they qualify, they can earn additional tickets. If they decide to finance with us more tickets.

Misleading Collection Scripts Cost Financial Institution $28.5 Million

10/18/2020

In its $28.5 million settlement with Navy Federal Credit Union (NFCU), the Consumer Financial Protection Bureau (CFPB) stated that NFCU's collection letters contained material misrepresentations – or unfair or deceptive abusive acts or practices – that were likely to mislead consumers; how did NFCU's templates violate UDAAP?

Add Bank Fees Paid in Cash to CTR?

10/18/2020

Should bank fees (Cashier Check purchase fee of $6.00) paid by the customer in cash, be added to their current CTR? If so, would the bank be the benefactor and the customer the transactor?

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