02/02/2004
I have an application which was withdrawn. The purpose is for earnest money on the purchase of a house. The amoount is $500.00. I am not sure if this is reportable on the HMDA LAR.
01/01/2004
What is compliance and how much is enough? The recent publication of the FAQs on the CIP rule provide some implicit guidance on where to draw the line.
11/01/2003
11/01/2003
We are about to enter a period of reporting information on high cost loans on the HMDA LAR. The fun begins on January 1, 2004 - actually the first business day after that date.
06/01/2003
Implementing the changes to HMDA is not going to be easy.
05/19/2003
I am compliance auditor of our bank. Recently when I audited our 2002 HMDALAR, I discovered in a number of cases that our HMDA reporter completed the Sex codes with a "1" to "A" and "2 to "CA"(male and female) and the Race code with a code other than the "6", "7" and "8"(Other, No information, and N/A) all in the absence of the monitoring information obtained directly or indirectly from the applicant/coapplicant. There is no evidence of the reporter having gone thru the process of obtaining the monitoring information, but rather he bases his judgement on the names and other personal information given on the loan documents. Can he do that? Instead, should be change those codes to "N/A" or "No Information"?
02/03/2003
We maintain a copy of our HMDA Disclosure Statement, for the two prior years, in one office in each MSA that we have an office. Should we also to maintain a copy of the modified LAR in multiple offices or can it be available only at our home office?
09/16/2002
Bankers Compliance Consulting Real Estate Loan Matrix. I found on this web site indicates that a closed end home equity loan is not HMDA reportable. I would like to know the reason the author made that decision. I find the reg excludes open end lines of credit only...
08/12/2002
The new changes to Regulation C do not appear to be consistent with HMDA. In the near future we will be seeking both ethnic and race information. HMDA only makes reference to race, not to ethnicity. I do not think that collecting information the same as OMB is justification for an expansion of Reg C beyond that of HMDA. The regulators appear to have gone beyond HMDA. Applicants will be asked their ethnicity AND their race. Hispanics may have no problem with the first question, but how do they answer the next question about race? I think confusion and misclassification will result.Even the example LAR included in the new staff interpretation (page 56) shows a Hispanic couple and he is 'white' and she is 'black'. No direction about the categories have been offered. I do not know how to train the lending staff on these new rules. can anyone get a ruling from the FED about the differences between HMDA and Reg C?
08/01/2002
The Federal Reserve Board has issued final HMDA rules for 2003 and for 2004. The expanded and much more complicated Loan Application Register ("LAR") comes into use at the beginning of 2004.