TWAS THE NIGHT BEFORE HMDA!
Twas the night before the HMDA changes took effect,
And Visions of "demographic information" were making me a wreck
Our business is always changing, and accurate data is needed,
Now we have 48 separate fields that must be completed.
Pre-quals don't count, but Pre-Approvals do,
Why can't I get the Adverse Action to come through?
A requirement to report which AUS to Submit,
My LOS has lost track ...My Underwriters might QUIT!
My borrower has indicated they do not wish to Report,
The processor is unsure and wants their Passport.
Fair Lending Analysis is promising! HMDA Data Is Clear.
No signs if Disparate Treatment, Now the examiner is my only fear!
Policies and Procedures are documented and known,
LO's have been trained what to say when the app is by Phone!
IT is always helpful when the data has been Scrubbed,
All this to ensure that no protected class has been Snubbed.
Reporting isn't due until Twenty-Nineteen,
Figuring this out is borderline Obscene!
Then all of a sudden...came the sound of a bell;
No, it's not Santa-it's the ring from my cell.
I sprang up to answer, still tucked in my bed,
It's my Board of Directors all filled with dread.
More Efficiency and Profit is at the top of their pile,
requesting more staff will surely result in denial.
And for all who think the implementation may be delayed,
I promise you the new HMDA Regulation is here to stay!
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