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#2080537 - 05/26/16 01:11 PM
Re: Final Rule Issued
Kathleen O. Blanchard
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Power Poster
Joined: Aug 2001
Posts: 7,351
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Well, we are all in this together! It will be exciting (in one way or another!) ....I'm not sure the term "exciting" is an accurate description. I can think of other, better choice words for the upcoming mess.
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The more you sweat in training, the less you bleed in battle.......
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#2080708 - 05/26/16 07:08 PM
Re: Final Rule Issued
TMatt87
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Diamond Poster
Joined: Dec 2013
Posts: 1,399
CA
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I think this will be much, much worse than TRID...
Our LAR is going to grow from about 1700 items to an estimate 5000.... Hope the departments get qualified HMDA staff because there is no way in [censored] this can fall on compliance's shoulders.
I think banks will be getting raked over the coals on this for the next decade. Havent heard anything about a grace period or changed permissible error percentage. If you fail an exam youll be scrubbing ALL of the new loans and ALL of the new fields. I cant even imagine. Might be very nice to be a consultant over the next 10 years haha.
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.
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#2080710 - 05/26/16 07:12 PM
Re: Final Rule Issued
TMatt87
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Power Poster
Joined: Oct 2009
Posts: 9,088
OK
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Makes me groan every time i realize that the only reason we're a HMDA reporter is the one (very small compared to other MSAs) MSA we have a branch in, which accounts for maybe 15% of our LAR. The other 85% of our LAR entries are in areas that would, on their own, never make it onto a LAR because they're outside of an MSA.
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#2080767 - 05/26/16 09:44 PM
Re: Final Rule Issued
TMatt87
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Power Poster
Joined: Oct 2009
Posts: 9,088
OK
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I do agree with that KB....never really made sense to me either.
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#2080772 - 05/26/16 09:53 PM
Re: Final Rule Issued
TMatt87
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Power Poster
Joined: Oct 2009
Posts: 9,088
OK
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I would like that change. Maybe that would exempt us (but i doubt it).
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#2080775 - 05/26/16 10:23 PM
Re: Final Rule Issued
TMatt87
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Diamond Poster
Joined: May 2011
Posts: 1,984
Idaho
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I'm a one person HMDA show with a LAR estimated to be about 1500 by 2018. It would probably be manageable if that we my sole responsibility, but I'm also the TRID guy, and the CRA guy and the Flood Insurance guy, and..... Should be fun.
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#2080796 - 05/27/16 12:49 PM
Re: Final Rule Issued
Kathleen O. Blanchard
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Power Poster
Joined: Jul 2002
Posts: 5,568
New Jersey
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And please prepare. Do not wait until late in 2017, or worse, until you start to enter loans on a 2018 LAR, to study how to complete each field. It is complex. I absolutely agree with Kathleen on this. I've already started educating the commercial loan department on HMDA itself. They really had no idea it affects multifamily, investor-owned residential, and mixed-use with a majority residential use loans. As I did with TRID, I've started putting out little bulletins about the HMDA changes to the entire lending staff. My biggest concern is with the commercial area. On the residential side, we will be capturing the required information through our LOS. The commercial side does not use an LOS, so I'm trying to figure out how to automate capture of the data.
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Management is doing things right; leadership is doing the right things. Peter Drucker
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#2085496 - 06/27/16 10:07 PM
Re: Final Rule Issued
TMatt87
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Gold Star
Joined: Oct 2014
Posts: 291
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Based on what I understand, we start collecting, per the new rule, on 1/1/2018. Is this based on loan applications received on or after 1/1/2018?
For example, what if we have an application in December 2017, but the loan doesn't get approved and closed until 2018?
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#2085497 - 06/27/16 10:19 PM
Re: Final Rule Issued
TMatt87
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Diamond Poster
Joined: May 2011
Posts: 1,984
Idaho
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It is based on action date, so if you start an application in 2017 but it doesn't reach final action until 2018, you will have to report on the 2018 LAR under the new rules. The one exception is the ethnicity, race, and sex information. For applications started in 2017, it will be reported in the same way as it is currently reported (no sub-categories).
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#2085718 - 06/28/16 08:15 PM
Re: Final Rule Issued
TMatt87
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Power Poster
Joined: Oct 2009
Posts: 9,088
OK
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It is based on action date, so if you start an application in 2017 but it doesn't reach final action until 2018, you will have to report on the 2018 LAR under the new rules. The one exception is the ethnicity, race, and sex information. For applications started in 2017, it will be reported in the same way as it is currently reported (no sub-categories). Matt....i'm not very far along yet on this......where is the citation or interpretation that applications started in 2017, but closed in 2018, will have the GMI reported per 2017 rules? Thanks.
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#2085736 - 06/28/16 08:39 PM
Re: Final Rule Issued
TMatt87
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Diamond Poster
Joined: May 2011
Posts: 1,984
Idaho
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This is from the small entity guide:
Because the 2015 HMDA Rule changes the information that must be included on an Application form or other collection form, Financial Institutions must revise their forms. A Financial Institution must use the revised collection or Application form for Applications received on or after January 1, 2018. For Applications received prior to January 1, 2018, the Financial Institution does not use the revised collection form, but collects applicant information using a collection form that complies with the Regulation C requirements in effect prior to January 1,2018. The 2015 HMDA Rule provides a transition provision that allows a Financial Institution to report the applicant’s ethnicity, race, and sex required under the Regulation C requirements in effect at the time that the Financial Institution collects the information, not when the Financial Institution takes final action on the Application. Comment 4(a)(10)(i)-2.
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All opinions are my own, not my employer's
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#2085743 - 06/28/16 08:46 PM
Re: Final Rule Issued
TMatt87
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Diamond Poster
Joined: May 2011
Posts: 1,984
Idaho
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And this from the final rule, page 739:
2. Transition rule for applicant data collected prior to January 1, 2018. If a financial institution receives an application prior to January 1, 2018, but final action is taken on or after January 1, 2018, the financial institution complies with § 1003.4(a)(10)(i) and (b) if it collects the information in accordance with the requirements in effect at the time the information was collected. For example, if a financial institution receives an application on November 15, 2017, collects the applicant’s ethnicity, race, and sex in accordance with the instructions in effect on that date, and takes final action on the application on January 5, 2018, the financial institution has complied with the requirements of § 1003.4(a)(10)(i) and (b), even though those instructions changed after the information was collected but before the date of final action. However, if, in this example, the financial institution collected the applicant’s ethnicity, race, and sex on or after January 1, 2018, § 1003.4(a)(10)(i) and (b) requires the financial institution to collect the information in accordance with the amended instructions.
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All opinions are my own, not my employer's
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#2085750 - 06/28/16 08:56 PM
Re: Final Rule Issued
TMatt87
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Power Poster
Joined: Oct 2009
Posts: 9,088
OK
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Thank you TMatt.
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#2094630 - 08/22/16 09:48 PM
Re: Final Rule Issued
TMatt87
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Gold Star
Joined: Apr 2016
Posts: 364
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I am little late to this party, but quick question: does anybody know, or think, if a new GIR will be issued? Also, regarding the link that started this thread, is that the best place to look to find the changes (or summary of) taking place? I am going cross-eyed trying to read through it!
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