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#2165326 - 02/21/18 05:38 PM New HMDA Guide Published at FFIEC Site
Kathleen O. Blanchard Offline

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#2165334 - 02/21/18 06:19 PM Re: New HMDA Guide Published at FFIEC Site Kathleen O. Blanchard
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Between the lines
grin
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#2165340 - 02/21/18 06:28 PM Re: New HMDA Guide Published at FFIEC Site Kathleen O. Blanchard
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So is this considered "official" guidance?
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#2165341 - 02/21/18 06:28 PM Re: New HMDA Guide Published at FFIEC Site Kathleen O. Blanchard
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Considering the CFPB also sent out a notice, I would think it would have to be.
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#2165343 - 02/21/18 06:31 PM Re: New HMDA Guide Published at FFIEC Site Kathleen O. Blanchard
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This made me very happy today. smile
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#2165344 - 02/21/18 06:33 PM Re: New HMDA Guide Published at FFIEC Site Kathleen O. Blanchard
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This jumped out at me on page V:

Additionally, this Guide is not a substitute for the requirements for filing the reportable data. The Filing Instructions Guide is the definitive source for information regarding the filing requirements and is available at www.consumerfinance.gov/data-research/hmda/for-filers.5

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#2165349 - 02/21/18 06:37 PM Re: New HMDA Guide Published at FFIEC Site Kathleen O. Blanchard
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I imagine the FIG would have to be the 'final word', but to me it misses all the 'explanations of why you report what you report'.
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#2165353 - 02/21/18 07:20 PM Re: New HMDA Guide Published at FFIEC Site Kathleen O. Blanchard
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I always thought the GIR was the definitions of what to file while the FIG was the how to file part.

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#2165364 - 02/21/18 08:12 PM Re: New HMDA Guide Published at FFIEC Site Kathleen O. Blanchard
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I haven't had a chance to read through this yet, does it provide different info than all the previously released CFPB documents? A quick scan to me looks like it just incorporates the CFPB content we've all already seen, and nothing new, am I missing something in the details?
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#2165365 - 02/21/18 08:16 PM Re: New HMDA Guide Published at FFIEC Site Kathleen O. Blanchard
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I did a fairly deep scan (though it was a scan) and it appears to be just a compilation of existing CFPB documents. I really didn't see anything that stuck out to me as new.
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#2165384 - 02/21/18 10:21 PM Re: New HMDA Guide Published at FFIEC Site Kathleen O. Blanchard
ahou Offline
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Very disappointing. A few pages of summary info and the rest is the CFPB stuff and the regulation/commentary.
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#2165398 - 02/21/18 11:46 PM Re: New HMDA Guide Published at FFIEC Site Kathleen O. Blanchard
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I'm actually relieved. We have so much guidance from the CFPB spread out in various documents, the last thing I need is something from the FFIEC muddying the waters at this point. Can you imagine the issues if they interpreted a sentence differently than the CFPB??
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#2165489 - 02/22/18 07:32 PM Re: New HMDA Guide Published at FFIEC Site GTS333
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Originally Posted By GTS333
Can you imagine the issues if they interpreted a sentence differently than the CFPB??


We'll leave it to the examiners to come up with their own interpretations.
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#2165495 - 02/22/18 07:45 PM Re: New HMDA Guide Published at FFIEC Site ahou
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Originally Posted By ahou
Very disappointing. A few pages of summary info and the rest is the CFPB stuff and the regulation/commentary.


Agreed. I was expecting something similar to the old GIR guide. This is just all the same information they already have out, packaged into one document.

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#2165497 - 02/22/18 07:56 PM Re: New HMDA Guide Published at FFIEC Site John Burnett
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Originally Posted By John Burnett
Originally Posted By GTS333
Can you imagine the issues if they interpreted a sentence differently than the CFPB??


We'll leave it to the examiners to come up with their own interpretations.


Still waiting on the FDIC to come up with their own letter explaining how they interpret everything totally differently....they seem to love to interpret regulations they didn't write.
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#2165499 - 02/22/18 07:59 PM Re: New HMDA Guide Published at FFIEC Site raitchjay
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out of the frying pan...
Originally Posted By raitchjay
Originally Posted By John Burnett
Originally Posted By GTS333
Can you imagine the issues if they interpreted a sentence differently than the CFPB??


We'll leave it to the examiners to come up with their own interpretations.


Still waiting on the FDIC to come up with their own letter explaining how they interpret everything totally differently....they seem to love to interpret regulations they didn't write.


And don't forget requiring all sorts of little weird stuff that isn't anywhere in the regulation, or that possibly is a carry-over from old regulation that no longer applies.
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#2165502 - 02/22/18 08:05 PM Re: New HMDA Guide Published at FFIEC Site Kathleen O. Blanchard
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Y'all are giving me such good warm fuzzies for data integrity exam next week. crazy
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#2165503 - 02/22/18 08:06 PM Re: New HMDA Guide Published at FFIEC Site Kathleen O. Blanchard
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I'm not even regulated by the FDIC here...i just always used to get a kick out of their letters explaining how HMDA wasn't really properly done the way we thought it was done. smile
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#2165507 - 02/22/18 08:07 PM Re: New HMDA Guide Published at FFIEC Site Kathleen O. Blanchard
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Switch to a national charter, lol.

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#2165509 - 02/22/18 08:17 PM Re: New HMDA Guide Published at FFIEC Site Compliance NABW
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Originally Posted By JPC
Switch to a national charter, lol.


A-freaking-men!

I know it costs more, but I'm so thankful for only one set of examiners that don't sweat as much small stuff.
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#2165510 - 02/22/18 08:21 PM Re: New HMDA Guide Published at FFIEC Site Kathleen O. Blanchard
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OCC? We're governed by the Fed, and for the most part, they are reasonable.
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#2165512 - 02/22/18 08:26 PM Re: New HMDA Guide Published at FFIEC Site Kathleen O. Blanchard
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I liked the FRB...they were really good. From what I've ever seen/heard, the OCC were not very well "trained" .
Last edited by RR Joker; 02/22/18 08:27 PM.
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#2165518 - 02/22/18 08:46 PM Re: New HMDA Guide Published at FFIEC Site raitchjay
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Originally Posted By raitchjay
OCC? We're governed by the Fed, and for the most part, they are reasonable.


Yes, sir. My old crew smile. I thought the FRB fellows were pretty tip-top as well.

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#2165520 - 02/22/18 08:51 PM Re: New HMDA Guide Published at FFIEC Site RR Joker
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Originally Posted By RR Joker
I liked the FRB...they were really good. From what I've ever seen/heard, the OCC were not very well "trained" .


I don't exactly know how other Agencies do it, but I felt that the OCC training was pretty good. Remember though that Safety and Soundness is more of a priority with the OCC. So, yes, from a consumer compliance standpoint you are pretty much on your own to an extent. This is also because the OCC runs an exam all in one shot, rather than having separate S&S and Compliance exams. So, in many instances the Compliance piece is pretty limited. There were only 3 mandatory reviews for consumer compliance that we had to "cross off the list" at each exam. I started to dislike doing Compliance, because I would cite a bunch of violations, find a bunch of issues and the EIC would kind of poo-poo it. But, if a credit was getting downgraded, then everybody was up in arms and ready to tinkle their pants. Hence, why the CFPB came about and took Compliance stuff away. I remember one bank, they had a flood violation cited every exam for 6-7 years straight, but it was a different part of the Reg. each time. The District Compliance Head was like, "it's not a pattern or practice" (for determining CMPs, etc.), I was like, "If this isn't a pattern or practice, then what the heck is!!?"
Last edited by JPC; 02/22/18 08:57 PM.
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#2167596 - 03/12/18 02:00 PM Re: New HMDA Guide Published at FFIEC Site Kathleen O. Blanchard
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Is there a typo on page 239 of the GIR guide? It states the APR is to be reported to 2 decimal places:


Enter the rate spread to two decimal places, and use a leading zero. For example, enter 03.29. If the difference between the APR and the average prime offer rate is a figure with more than two decimal places, round the figure or truncate the digits beyond two decimal places.


Everything I have seen, including the FIG, reflects reporting to 3 decimal places, is that the consensus?

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