I'm having a hard time figuring out when we should start transitioning to the 2018 data. Originally, I thought based on the comment below that we wouldn't turn the 2018 switch until 1-1-2018... but our mortgage group feels like they should be practicing early. What are you suggesting for your banks?

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.

I don't intend to have them start collecting disaggregate info until application taken 1-1-18. In an effort to make a 'clean' start.

Same here.

Not until we have to. 1-1-18

Thanks for your responses! I agree that 1-1-18 is the cleanest, and I was actually surprised they wanted to get a head start, but didn't want to make an unpopular decision without sound reasoning.

Actually - I just found something on the CFPB's website that confirms (for me at least) this is the expectation on the HMDA Rule Key Dates Timeline.

2017
Q1 – Q4
Collect 2017 data as required under the current rule1 (for reporting in 2018)

2018
Q1 – Q4
Collect 2018 data as required under the new rule2 (for reporting in 2019)

This link is to a form from the CFPB. We are starting before Jan. 1 because we have a hybrid system that has too many questions about data extraction. Of course we will report as appropriate. We want time to test and adjust. (I hope the link works.)

https://s3.amazonaws.com/files.consumerf...llection_v2.pdf

We are starting before Jan 1 too. Testing and adjusting as well. Plus we have a whole new department (consumer) that is brand new to collecting and they just got a brand new LOS which is different from the LOS we currently use in mortgage.

We don't want to wait until 1/1 to figure out how the whole process A-Z is going to work.

We're starting early as well.

I know quite a few that have already started to work the kinks out.

We're definitely working the kinks out now - just not intending to "turn it on" until January.

We started in our Secondary Market last week and start our in-house on Monday.
Lots of training just on the new GMI alone.
We wanted time to "practice" so that we are in the habit and somewhat familiar with the new form by the time it's required on Jan 2nd.

I'm having trouble getting this straight in my head...

1/1/18 the coverage of HMDA changes on consumer transactions to include ALL dwelling secured apps.

What about this: Today we get an app for cash-out refi (closed end) to fund a family vacation, secured by their home. Should we collect data?? Under 2017 rules, it isn't HMDA reportable. But it will likely close in 2018. Should we collect Demographic Information now?

Why isn't it reportable under 2017 rules? Cash out refi....or home equity loan?

As you stated, under the 2017 rules, that is not a HMDA reportable application. If you anticipate it closing in 2018, you can (and should) collect Demo Info.
https://s3.amazonaws.com/files.consumerf...-Collection.pdf

Good point raitchjay. I assume Rebekah meant it was a home equity loan (not a refinance + cash out).

David.....what if you don't anticipate a home equity loan closing in 2018, so you don't gather the GMI...but then for unforeseen reasons, it DOES close in 2018? How would you report the GMI fields?

Should you try to gather once the calendar rolls to 2018?

I would think you should begin attempting to collect it as soon as you know the loan will roll over year end.

If you have a non-HMDA application taken in 2017 with a planned 2017 closing that is delayed until 2018 (thus it will be HMDA reportable), you must collect GMI or DMI at the time you determine that it will be HMDA reportable. You don’t get to “not collect”. If you collect the info in 2017, then it can be GMI or DMI. If you collect it in 2018, then you must collect DMI.

Thank you both.

We report unsecured home improvement loans. If we receive an application in 2017 and decision the app in 2018 is the transaction reportable in 2017? Or do we not report it in 2018? I can't get the timing straight in my head for loans that are reportable now but will not be reportable in 2018.

Thanks

If the loan is decisioned/closed in 2018, it goes by 2018 reporting rules. So....it would not be reportable and you wouldn't go back and add it to your 2017 LAR either.

HMDA applications are always reported in the year in which final action is taken.

Thanks everyone! Yes, in my scenario I meant a home equity loan. My brain is just fried!