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#2100947 - 09/29/16 01:30 PM Use of 2016 URLA
ComplyGuy Offline
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The CFPB approved the use of the new URLA for applications in 2017 and allowed lenders to begin collecting the new monitoring data at that same time. Sounds to me like this will be a big help in preparing for the HMDA changes in 2018.

https://www.federalregister.gov/document...d-home-mortgage

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#2100950 - 09/29/16 01:48 PM Re: Use of 2016 URLA ComplyGuy
Kathleen O. Blanchard Offline

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But bear in mind that there are risks and vendors are not ready.

You will still have data on customers regardless of "practicing". Could that data be subpoenaed? I would consider it carefully and discuss with legal counsel before jumping.
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#2100976 - 09/29/16 03:06 PM Re: Use of 2016 URLA ComplyGuy
ComplyGuy Offline
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I think this will help speed up the vendors preparedness. With this ruling now they could implement before 2018. Without it, I wouldn't have been expected to implement until 2018 and then there would be problems when . This gives time to work out the kinks.

What legal risks do you foresee? Potential for fair lending violations?

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#2101094 - 09/29/16 08:47 PM Re: Use of 2016 URLA ComplyGuy
Kathleen O. Blanchard Offline

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Yes, potential for fair lending. Also, for vendors, they have their schedules set, working on the TRID updates, finishing MLA (!!!) and working on HMDA. We will see if they can bring this date forward.

If I wanted to "practice" (which does have value), I would start with my lowest risk line of business (fair lending risk).
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www.kaybeescomplianceinsights.com

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#2101248 - 09/30/16 05:00 PM Re: Use of 2016 URLA ComplyGuy
David Dickinson Offline
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KB brings up some great "costs" vs. the "reward" of implementing all of the changes at once. My first thought is I would wait until the 4th quarter of 2017 to introduce the new URLA so you can "practice" - but not too soon.
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#2101294 - 09/30/16 06:54 PM Re: Use of 2016 URLA ComplyGuy
Sewanee, CRCM Offline
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Does anyone have any thoughts about whether the new URLA will be required (or considered best practice) for consumer-purpose home equity and/or HELOCs? We use the current version only in our residential lending division that engages in secondary market activity. The equity and HELOC loans use a version of the ECOA model form generated off LaserPro.
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#2101343 - 09/30/16 10:52 PM Re: Use of 2016 URLA ComplyGuy
Kathleen O. Blanchard Offline

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The URLA continues to be optional, a model form. You will need to update any demographic data gathering that you do to comply with the revised HMDA rule; that updated data gathering is incorporated into the revised URLA.
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www.kaybeescomplianceinsights.com

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#2102544 - 10/11/16 05:47 PM Re: Use of 2016 URLA ComplyGuy
Wannaknow Offline
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I don't see where the co-borrowers information is collected. Do we need to use a separate application for the co-borrower information?

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#2102552 - 10/11/16 06:16 PM Re: Use of 2016 URLA ComplyGuy
Island Dreaming Offline
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On page 11 of the linked document, there is a section for 'Additional Borrower' - I think that's what you are looking for.
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#2102558 - 10/11/16 06:34 PM Re: Use of 2016 URLA ComplyGuy
Wannaknow Offline
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Thank you.

So the co-applicant has to fill out a separate application. Interesting and very time consuming. How many people will just say "see" or "same" as borrower application.

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#2102607 - 10/11/16 08:14 PM Re: Use of 2016 URLA ComplyGuy
Island Dreaming Offline
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It isn't actually a separate application - several of the sections say information was included on applicants application - it's more the co-applicants personal info, employment info and gmi. The co-applicant signature line is on the primary applicants form.
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#2104107 - 10/21/16 05:39 PM Re: Use of 2016 URLA ComplyGuy
Kathleen O. Blanchard Offline

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The new form is actually created to be an electronic dynamic form. As stated above, the co-applicant who has no separate assets just enters their personal info and directs to the applicants data for the rest.
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Kathleen O. Blanchard, CRCM "Kaybee"
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The HMDA Academy
www.kaybeescomplianceinsights.com

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#2104461 - 10/25/16 03:00 PM Re: Use of 2016 URLA ComplyGuy
Kathleen O. Blanchard Offline

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Just FYI because Fannie/Freddie is "un-issuing" the form on November 1 pending implementation. I heard back from them today (I had asked about using a paper form for in house loans, for example).

For non GSE loans, you can start to use the new form in 2017. So if you want to use it in paper form or you have a vendor who is ready, it is allowed for non GSE loans only.
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Kathleen O. Blanchard, CRCM "Kaybee"
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The HMDA Academy
www.kaybeescomplianceinsights.com

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#2105094 - 10/28/16 04:02 PM Re: Use of 2016 URLA Kathleen O. Blanchard
TMatt87 Offline
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Originally Posted By Kathleen B
Just FYI because Fannie/Freddie is "un-issuing" the form on November 1 pending implementation. I heard back from them today (I had asked about using a paper form for in house loans, for example).

For non GSE loans, you can start to use the new form in 2017. So if you want to use it in paper form or you have a vendor who is ready, it is allowed for non GSE loans only.


Has Fannie/Freddie put anything out to this effect, or are we just awaiting an announcement on 11/1? My CO is looking for something to back this up.

Thanks!
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#2105194 - 10/28/16 08:36 PM Re: Use of 2016 URLA ComplyGuy
Kathleen O. Blanchard Offline

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They have said they will announce everything on 11/1.
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The HMDA Academy
www.kaybeescomplianceinsights.com

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#2105665 - 11/02/16 03:26 PM Re: Use of 2016 URLA ComplyGuy
Catm1991 Offline
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GSE --?

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#2105680 - 11/02/16 04:07 PM Re: Use of 2016 URLA ComplyGuy
Kathleen O. Blanchard Offline

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Government sponsored entity.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2105682 - 11/02/16 04:07 PM Re: Use of 2016 URLA Kathleen O. Blanchard
Kathleen O. Blanchard Offline

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Fannie did publish an announcement regarding the changed effective date.

Link to announcement
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Kathleen O. Blanchard, CRCM "Kaybee"
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www.kaybeescomplianceinsights.com

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#2105684 - 11/02/16 04:12 PM Re: Use of 2016 URLA ComplyGuy
Sunshine Lady Offline
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Thank you so much Kathleen.
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#2105692 - 11/02/16 04:45 PM Re: Use of 2016 URLA Kathleen O. Blanchard
Catm1991 Offline
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Thank you.

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