2017 HMDA Process Changes

The HMDA process is changing in 2017 and it affects all HMDA reporters, not just those using the FFIEC software (which is going away after the 2016 submissions).

I am presenting a webinar for BOL on November 17th going over the changes in detail and what you need to think about and do to prepare. Registration Link

You can read a quick overview of the changes in this article.

http://www.consumerfinance.gov/data-research/hmda/des-update-2017

My head is spinning on a Monday morning considering all of this. Long and short of 2017 data collection is that we collect the same data we are today but have to report it differently, yes? Or am I losing my marbles and there's more changing in 2017 before the massive 2018 change?

The only other change is the institutional coverage. The volume test has changed from 1 purchase (or refi of purchase) to 25.

Correct - the main change will be the new reporting process (2017 data reported in 2018).

Hooray Monday!

Thanks. Anyone got the inside line on powerball numbers to retire before this hits?

The more complex HMDA becomes, the better my job security is. HMDA specialists are in high demand right now and I don't see that slowing down anytime soon.

Incredibly true, but the more headaches for us in implementation. I've seen several comments about this being a favorite reg and I'm in that camp...just trying to break down the regulatory changes for my shop is a headache with everything else going on.

Right. Job security....why I vote for the dems......I don't want Dodd Frank repealed.

The big change for 2017 is the process change.

Article

My article explaining the changes - they affect all HMDA reporters, even those with vendor software. One important change is that all edits, including the macro edits now received via email, will be received and processed online prior to submission. Allow time for that.

Nice article Kathleen B.

One item I wanted to raise that I haven't seen discussed here is applications received in 2017, but on which final action is taken on or after 1/1/2018. Don't banks need to collect (and ultimately including in their 2018 reporting) the new expanded HMDA data set prior to 1/1/2018 in that example? That's more than just a process change in 2017, it is also a very real technical change, no?

Yes. I have harped on this many times in webinars, articles, etc. if the action date in in 2018, even if the application was taken in January 2017, the application will be reported under 2018 rules. There is a transition rule for demographic data but not for anything else

Great, thanks Kathleen - I just wanted to make sure I wasn't missing something as some of the comments above in this thread seem to suggest there is nothing but the change to the institutional coverage test occurring in 2017. Obviously that's not the only pitfall to watch out for.

Thanks again.

And the process change for 2017 is actually a big deal! No last minute submissions. You have to clear all edits including macro edits that used to be post submission prior to the file being accepted.

Any ideas on how this new process will be monitored for input accuracy at point of entry on loan platforms? This process and data collection seems overly complicated and lends itself to enormous input errors leading to a great many edits. Is there a costs/benefits analysis of collecting this data for the public? Seems to me about the time we begin to understand the "how to" somebody comes along and thinks they have to change it.