I just found out that we may now be HMDA reportable. Any ideas on where to even start?

Here is alink to one website that has useful tools. Under the heading COVERAGE CHARTS, you can find a multi-page tool to help you identify whether you have a HMDA reportable loan:

https://www.consumerfinance.gov/policy-compliance/guidance/hmda-implementation/

The same link above provides an Institutional Coverage Chart, which would help you determine if you are liable for reporting.

This link provides a refernce for filing out the reportable HMDA information, complete with descriptions of the various responses and quick links to the part of Reg C that covers any particular line item.

https://files.consumerfinance.gov/f...orting-overview-reference-chart-2019.pdf

These two links will help you dive right in.

A more indepth document can be found here https://www.ffiec.gov/HMDA/guide.htm 2018 Guide to HMDA Reporting


GOOD LUCK

Well, welcome to the wonderful world of HMDA.

To answer your question, I should ask: Are you required to report for 2019, or will you start collecting in 2020? Either way, you may want to get some outside assistance to get caught up on the complex world of HMDA. If you must report for 2019, you are going to be significantly behind the curve and I would highly recommend hiring someone to do they best they can to catch you up. If you will be reporting for 2020, I would start the learning process today and recommend taking a class/a few webinars on HMDA (BOL offers several in their store). Even for small filers, in-person seminars can easily take a full day, and that really doesn't cover all of the quirks that can come with HMDA.

In addition to using training to fast track you to getting caught up, I would highly recommend that you become familiar with the documents Melissa S provided. These resources are a bit easier to chew than the regulation itself, but you can always view the regulation (and commentary) here: https://www.bankersonline.com/regulations/12-1003-000

Finally, as you have questions on HMDA, feel free to post questions here as there are many BOLers willing to help you out - since we all love HMDA so much.

We are going to have to report for 2019

And you're just finding this out?

Well, the first place to start is going to be to stop the bleeding. As you already have violations for not collecting demographic information (DI) when required, I would start by immediately training your team on how to identify a HMDA reportable loan as DI is required for anything that must be reported (yes, the HMDA DI rules are different than the Reg B GMI rules). Beyond that, I still suggest hiring someone immediately to assist you in getting caught up as it would be very challenging to get up-to-speed on HMDA this late in the game, especially if you don't have experience in HMDA. Best of luck and let us know if you have questions.