As "HMDA Queen", and being the person who needs written timelines, here is what we have developed:
2016
Read the new Reg C, front to back and made notes.
2017 Q1-2:
Formed a "HMDA 2018 Implementation Team" composed of me, my boss/our compliance officer, manager of centralized loan documentation, SM compliance analysts, and SM director of quality control. We attended external webinars together and discussed our Q&As from that.
I read the CFPB's proposed amendments front to back, made questions, and we met to discuss them.
Presented a HMDA 2018 Overview to the bank's Compliance Committee (comprised of executives, lenders from retail/commercial/SM, compliance department staff, etc). Did not go into detail but I am pretty proud of the slides - keep in mind if you are doing your own training that people are not paying attention to the right stuff but they DO LIKE GRAPHICS/MEMES
2017 Q3:
Our LOSs should have full testing capabilities any day now (goal July 1st; LaserPro just released an update).
Am still waiting on approval to purchase our LEI
so I guess I will input a 'fake' LEI to begin testing.
By September we should have the LOS process down somewhat and will draft procedures for in-house and SM. We will then take a lender/assistant pair from each division (retail, corporate/commercial, SM) and use those procedures to give them training. We will use their feedback from the frontline standpoint to tweak our procedures to be used with all lenders in Q4.
2017 Q4:
All lending staff will be trained: SM, lenders/assistants from retail and corporate, and centralized loan doc (probably by Nov 1).
At that time, they will be instructed to begin using the expanded GMI addendum form in lieu of the current GMI form.
Field-by-field will not be trained on since centralized loan doc reports this for the lenders, but they will receive a guide (right now it's a draft) that I made that is SOOO long and is our internal instructions for what/how to report in each field. I translated from CFPB-talk to English.