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#2198128 - 11/13/18 09:22 PM Voluntary Reporting of Exempt Data Points
LostFan Offline
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A bank has the option to voluntarily report exempt data points for transactions that qualify for a partial exemption. What reasons would compel
a bank to voluntarily report exempt data points?

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#2198129 - 11/13/18 09:30 PM Re: Voluntary Reporting of Exempt Data Points LostFan
rlcarey Offline
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Lack of reasoning?
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#2198140 - 11/13/18 11:06 PM Re: Voluntary Reporting of Exempt Data Points LostFan
David Dickinson Offline
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I have the same question. Some are saying it's a lot of work to remove the data they have already entered. In my opinion, it's worth it.
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#2198149 - 11/14/18 03:19 AM Re: Voluntary Reporting of Exempt Data Points LostFan
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If a bank wanted to keep the data for their own use, but take advantage of the exemptions for reporting; how would they submit that Excel file?

Can they simply make a copy of the report on another TAB within the original Excel file, or should they copy the whole file into a separate Excel report with only the 2 tabs as designed by CFPB?

I do not submit so I am wondering if it was simply a matter of an additional tab, if CFPB's program would know to process the tab with the exemptions.

Thanks,
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#2198158 - 11/14/18 12:37 PM Re: Voluntary Reporting of Exempt Data Points LostFan
Adam Witmer Offline
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I haven't been involved in the submission process in years, but I would think that you would not want the extra data points on a separate tab in excel. If I wanted to keep the extra data points for my records, I would save them on a separate file and then make sure they were completely removed from the file I was submitting.

Like Randy and David, I absolutely agree that it is worth removing the extra data points.
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#2198166 - 11/14/18 02:55 PM Re: Voluntary Reporting of Exempt Data Points LostFan
RR Joker Offline
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From the user/submitter standpoint, It will all depend on how my system handles this in December [proposed update]. If it's a seemless process, I'll not report exempt fields. If it would be terribly time consuming on my part, there is no way I will have time to make the adjustments. I'm completely up in the air at the moment, but from what I 'hear'....it should be a simple solution. Time will tell.
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#2198173 - 11/14/18 04:17 PM Re: Voluntary Reporting of Exempt Data Points LostFan
dottiec Offline
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We are with RR Joker- depends on the vendor updates. They haven't been real responsive to date, but we are hoping for the best.
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#2198176 - 11/14/18 04:35 PM Re: Voluntary Reporting of Exempt Data Points LostFan
LostFan Offline
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These are good comments. Thank you very much.

Do you foresee any concerns if a bank did not report exempt data points and elects to sell loans down the road?

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#2198215 - 11/14/18 07:26 PM Re: Voluntary Reporting of Exempt Data Points LostFan
David Dickinson Offline
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Quote:
Do you foresee any concerns if a bank did not report exempt data points and elects to sell loans down the road?

I'm not sure what reporting "exempt" has to do with selling loans in the future. I have no concerns.
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#2198259 - 11/15/18 03:40 AM Re: Voluntary Reporting of Exempt Data Points LostFan
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Selling your loans should not have any effect on the LAR that you file. However, it may be beneficial to have a conversation with your investor(s) to see what information they will expect to see with the loan you sell to them.

I'm hoping that they will provide their banks with a checklist of additional information that they will need for processing the loan rather than each bank trying to determine what they should send. For example, if you plan to assign a ULI, they might want that on the checklist, etc.
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#2198275 - 11/15/18 02:45 PM Re: Voluntary Reporting of Exempt Data Points LostFan
LostFan Offline
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Thanks David Dickinson and SMQ for the comments! They are greatly appreciated!

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#2198285 - 11/15/18 04:04 PM Re: Voluntary Reporting of Exempt Data Points LostFan
GTS333 Offline
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It's a good question - Wouldn't the purchaser who has to report the purchased HMDA loan have to report all of the exempt fields if the purchaser was not able to take advantage of the exemption?
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#2198291 - 11/15/18 04:30 PM Re: Voluntary Reporting of Exempt Data Points LostFan
David Dickinson Offline
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Quote:
It's a good question - Wouldn't the purchaser who has to report the purchased HMDA loan have to report all of the exempt fields if the purchaser was not able to take advantage of the exemption?

Yes they do. Some investors can extract the data but some are requiring the originator to hand them the data. IOW, the small lender doesn't get relief from these changes in the latter case. However, I'm not sure what that has to do with the small lender reporting their own data to the CFPB at the end of the year.

On a related note: I wrote a letter to the CFPB and my Congressional representatives about this. The small lender that has to report all of the data to the investors is not provided with relief. I used the words "disparate treatment" (on purpose). There are many data fields that allow investors to report NA on purchase loans, so why can't the investor simply report "Exempt" or "1111" as well?
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#2198301 - 11/15/18 04:58 PM Re: Voluntary Reporting of Exempt Data Points LostFan
GTS333 Offline
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Thanks David. To be clear a little more clear, I wasn't suggesting that it has an impact on the small lenders ability to report the smaller data set to the BCFP, but I was raising the issue to help more fully answer LostFan's question. I do think it is helpful to point out that it does create more work for those small lenders (and thank you for sending your letter to your Rep.). They are going to need to basically collect the full data set, then store that full data set somewhere so it can be sent to the purchaser, then scrub the second copy of that data set to inset the exempt data points before filing with the BCFP. If a small lender doesn't think that exposing their full HMDA data set will pose any real risk to them, then these are extra steps they technically don't have to take. I realize the majority opinion here is that sending more data than is necessary to the BCFP is ill-advised, but opinions will certainly differ on that somewhat based on workload.
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#2198430 - 11/16/18 02:41 PM Re: Voluntary Reporting of Exempt Data Points LostFan
RR Joker Offline
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Well dang. I guess this little gem is going to require some serious decision-making on how to proceed into the future...keep on collecting, but don't report the exempted fields, so the examiners will be happy or quit collecting them to make staff's life a little bit easier. crazy

this is what my provider is doing for institutions to handle the exemptions:

Flag records as partially exempt
Configure data points to be included or excluded from edit checks and your submission file
Maintain values for exempt data fields while still exempting them for the submission file
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#2198469 - 11/16/18 04:41 PM Re: Voluntary Reporting of Exempt Data Points RR Joker
RR Becca Offline
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out of the frying pan...
Originally Posted By RR Joker

this is what my provider is doing for institutions to handle the exemptions:

Flag records as partially exempt
Configure data points to be included or excluded from edit checks and your submission file
Maintain values for exempt data fields while still exempting them for the submission file


This is what our vendor is doing, as well. I fail to see how still having to input all of those fields on the front end is 'relief' in any way, shape, or form.
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#2198473 - 11/16/18 04:50 PM Re: Voluntary Reporting of Exempt Data Points LostFan
RR Joker Offline
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I still swear those vendors are the same under different names laugh!

Most likely I will eliminate the exempted fields from collection...If for no other reason then I don't want to have to think about what is and what is not exempt when I scrub wink

And I would like to give staff a little relief...they have really worked hard to get it right.
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#2198474 - 11/16/18 04:58 PM Re: Voluntary Reporting of Exempt Data Points LostFan
RR Becca Offline
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out of the frying pan...
I would love to give our front end staff a break on some of this stuff. A fair percentage of it is just plain dumb when you are dealing with itty-bitty-bank in-house lending. What I haven't figured out is exactly how to do so. smirk
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#2198493 - 11/16/18 05:56 PM Re: Voluntary Reporting of Exempt Data Points RR Joker
CompliantOkie Offline
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Originally Posted By RR Joker
IAnd I would like to give staff a little relief...they have really worked hard to get it right.
THIS!!!!! We all worked really hard to learn the new fields. It's nice but still annoying to now tell them forget all that information.

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#2198498 - 11/16/18 06:18 PM Re: Voluntary Reporting of Exempt Data Points RR Becca
RR Joker Offline
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Originally Posted By RR Becca
I would love to give our front end staff a break on some of this stuff. A fair percentage of it is just plain dumb when you are dealing with itty-bitty-bank in-house lending. What I haven't figured out is exactly how to do so. smirk

I'm starting to work on this project.
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