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#2165326 - 02/21/18 05:38 PM
New HMDA Guide Published at FFIEC Site
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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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Joined: Oct 2000
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Soaring over Georgia
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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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#2165344 - 02/21/18 06:33 PM
Re: New HMDA Guide Published at FFIEC Site
Kathleen O. Blanchard
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Joined: Dec 2002
Posts: 3,842
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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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The Swamp
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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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#2165364 - 02/21/18 08:12 PM
Re: New HMDA Guide Published at FFIEC Site
Kathleen O. Blanchard
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Joined: Jun 2010
Posts: 257
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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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Joined: Sep 2010
Posts: 2,662
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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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Adam Witmer, CRCM All statements are my opinion, not those of my employer, and should not be taken as legal advice. www.compliancecohort.com
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#2165384 - 02/21/18 10:21 PM
Re: New HMDA Guide Published at FFIEC Site
Kathleen O. Blanchard
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Joined: Aug 2002
Posts: 3,094
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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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Gold Star
Joined: Jun 2010
Posts: 257
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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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Joined: Oct 2000
Posts: 40,086
Cape Cod
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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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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#2165495 - 02/22/18 07:45 PM
Re: New HMDA Guide Published at FFIEC Site
ahou
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Joined: Oct 2015
Posts: 1,669
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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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Joined: Oct 2009
Posts: 9,108
OK
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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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Joined: Sep 2004
Posts: 5,249
out of the frying pan...
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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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#2165503 - 02/22/18 08:06 PM
Re: New HMDA Guide Published at FFIEC Site
Kathleen O. Blanchard
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Joined: Oct 2009
Posts: 9,108
OK
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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.
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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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Diamond Poster
Joined: Oct 2015
Posts: 1,669
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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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Joined: Jan 2006
Posts: 642
Missouri
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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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Power Poster
Joined: Oct 2009
Posts: 9,108
OK
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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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Posts: 20,656
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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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My opinion only. Not legal advice. Say you'll haunt me - Stone Sour
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#2165518 - 02/22/18 08:46 PM
Re: New HMDA Guide Published at FFIEC Site
raitchjay
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Joined: Oct 2015
Posts: 1,669
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OCC? We're governed by the Fed, and for the most part, they are reasonable. Yes, sir. My old crew . 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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Joined: Oct 2015
Posts: 1,669
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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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100 Club
Joined: Feb 2011
Posts: 144
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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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