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#2149876 - 10/16/17 02:17 PM
When are you "switching over"?
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Platinum Poster
Joined: Sep 2015
Posts: 501
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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.
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#2149878 - 10/16/17 02:25 PM
Re: When are you "switching over"?
Monster
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10K Club
Joined: Nov 2002
Posts: 20,656
The Swamp
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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.
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My opinion only. Not legal advice. Say you'll haunt me - Stone Sour
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#2149880 - 10/16/17 02:34 PM
Re: When are you "switching over"?
Monster
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Power Poster
Joined: Oct 2009
Posts: 9,290
OK
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Same here.
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I'm fixin' to fix that.
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#2149902 - 10/16/17 03:29 PM
Re: When are you "switching over"?
Monster
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Platinum Poster
Joined: Apr 2014
Posts: 697
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Not until we have to. 1-1-18
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Define Success on your own terms, achieve it by your own rules, and build a life you are proud of. Anne Sweeney
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#2149904 - 10/16/17 03:34 PM
Re: When are you "switching over"?
Monster
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Platinum Poster
Joined: Sep 2015
Posts: 501
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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.
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#2150100 - 10/17/17 04:19 PM
Re: When are you "switching over"?
Monster
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Platinum Poster
Joined: Sep 2015
Posts: 501
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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)
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#2150170 - 10/17/17 08:09 PM
Re: When are you "switching over"?
Monster
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Power Poster
Joined: Aug 2006
Posts: 4,266
Chillin an grillin
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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.
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HMDAHMDAHMDAHMDAHMDAHMDA
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#2150252 - 10/18/17 02:57 PM
Re: When are you "switching over"?
Monster
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Platinum Poster
Joined: Sep 2015
Posts: 501
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We're definitely working the kinks out now - just not intending to "turn it on" until January.
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#2154743 - 11/24/17 08:21 PM
Re: When are you "switching over"?
Monster
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Gold Star
Joined: Jan 2010
Posts: 293
Oklahoma
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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.
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Compliance - A Painful Addiction
All comments are mine & should not be taken as legal advice.
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#2155377 - 11/29/17 09:08 PM
Re: When are you "switching over"?
Monster
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Platinum Poster
Joined: Feb 2003
Posts: 879
Big Sky Country
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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?
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Me, Type A? Maybe - I'm not done analyzing it yet.
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#2155386 - 11/29/17 09:27 PM
Re: When are you "switching over"?
Monster
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Power Poster
Joined: Oct 2009
Posts: 9,290
OK
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Why isn't it reportable under 2017 rules? Cash out refi....or home equity loan?
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I'm fixin' to fix that.
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#2155388 - 11/29/17 09:28 PM
Re: When are you "switching over"?
Monster
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10K Club
Joined: Nov 2000
Posts: 18,765
Central City, NE
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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? 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
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#2155391 - 11/29/17 09:31 PM
Re: When are you "switching over"?
Monster
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Power Poster
Joined: Oct 2009
Posts: 9,290
OK
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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?
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I'm fixin' to fix that.
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#2155394 - 11/29/17 09:33 PM
Re: When are you "switching over"?
Monster
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Power Poster
Joined: Oct 2009
Posts: 9,290
OK
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Should you try to gather once the calendar rolls to 2018?
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I'm fixin' to fix that.
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#2155397 - 11/29/17 09:36 PM
Re: When are you "switching over"?
Monster
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Power Poster
Joined: Sep 2004
Posts: 5,249
out of the frying pan...
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I would think you should begin attempting to collect it as soon as you know the loan will roll over year end.
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You call it ADD. I call it multi-tasking.
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#2155399 - 11/29/17 09:40 PM
Re: When are you "switching over"?
Monster
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10K Club
Joined: Nov 2000
Posts: 18,765
Central City, NE
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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? 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 collectâ€. 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.
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#2155403 - 11/29/17 09:42 PM
Re: When are you "switching over"?
Monster
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Power Poster
Joined: Oct 2009
Posts: 9,290
OK
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Thank you both.
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I'm fixin' to fix that.
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#2155418 - 11/29/17 10:06 PM
Re: When are you "switching over"?
Monster
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Power Poster
Joined: Oct 2009
Posts: 9,290
OK
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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.
_________________________
I'm fixin' to fix that.
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