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#2099269 - 09/19/16 09:40 PM
How many FTE will you add due to the HMDA Overhaul
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Diamond Poster
Joined: Dec 2013
Posts: 1,399
CA
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Hello Everyone!
I am curious as to how many new personnel your institution is hoping to add to ensure data integrity under the updated HMDA rules.
I realize this poll does not take into account LAR entries, volume, etc. Please comment with your Asset Size and current and estimated HMDA LAR entries under the new rule. We are in preparations for staffing budget and I cannot find any articles on the increased staffing or expense due to the new rules.
Asset Size: $4.5B Current LAR: Roughly 1700 entries Estimated 2018 LAR: Roughly 4500-5000 entries
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.
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#2099344 - 09/20/16 02:02 PM
Re: How many FTE will you add due to the HMDA Overhaul
JC (Darth HMDA)
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Diamond Poster
Joined: May 2011
Posts: 1,984
Idaho
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For at least the first year, we aren't planning on adding any staff. Currently, it's just me. I want to see how much I can automate the process before adding staff.
Asset size: 1.2B Current LAR: 700 Estimated 2018 LAR: 1200-1400
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All opinions are my own, not my employer's
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#2099359 - 09/20/16 03:00 PM
Re: How many FTE will you add due to the HMDA Overhaul
JC (Darth HMDA)
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Power Poster
Joined: Apr 2005
Posts: 3,663
TN
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0 new staff but we are looking at purchasing HMDA/Fair Lending software.
Asset size 150mm Current LAR 130 Estimated 2018 LAR 200
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I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.
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#2099367 - 09/20/16 03:31 PM
Re: How many FTE will you add due to the HMDA Overhaul
David Dickinson
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Diamond Poster
Joined: Dec 2013
Posts: 1,399
CA
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You should add "0" to the poll. Good point David. My apologies. Thank you TMatt and Dani. Appreciate the feedback.
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.
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#2099369 - 09/20/16 03:32 PM
Re: How many FTE will you add due to the HMDA Overhaul
JC (Darth HMDA)
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Diamond Poster
Joined: Dec 2013
Posts: 1,399
CA
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It wont let me edit the post. Sorry!
_________________________
The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.
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#2099372 - 09/20/16 03:36 PM
Re: How many FTE will you add due to the HMDA Overhaul
JC (Darth HMDA)
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Power Poster
Joined: Oct 2009
Posts: 9,088
OK
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I'm just really dense i guess, but i can't make "FTE" convert to any words that make sense to me...i understand (i think) that you mean hiring new people, but what does FTE stand for?
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I'm fixin' to fix that.
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#2099379 - 09/20/16 03:44 PM
Re: How many FTE will you add due to the HMDA Overhaul
JC (Darth HMDA)
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Power Poster
Joined: Oct 2009
Posts: 9,088
OK
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Nevermind....full-time employees..ok.
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I'm fixin' to fix that.
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#2099380 - 09/20/16 03:46 PM
Re: How many FTE will you add due to the HMDA Overhaul
JC (Darth HMDA)
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Power Poster
Joined: Oct 2009
Posts: 9,088
OK
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I'm sure i will not be fortunate enough to have anybody hired specifically for this purpose....
Asset size: 250 million Current LAR: 200 Estimated 2018.....i'd guess 250-300
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I'm fixin' to fix that.
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#2099384 - 09/20/16 03:51 PM
Re: How many FTE will you add due to the HMDA Overhaul
JC (Darth HMDA)
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New Poster
Joined: Apr 2015
Posts: 8
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0 hires
170 mill current: 180 estimated: 180-200?
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#2099401 - 09/20/16 04:18 PM
Re: How many FTE will you add due to the HMDA Overhaul
JC (Darth HMDA)
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10K Club
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
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0
300 mil Current: 1000 Estimated: 1100
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I don't repeat gossip, so listen closely...
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#2099584 - 09/20/16 10:20 PM
Re: How many FTE will you add due to the HMDA Overhaul
JC (Darth HMDA)
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Diamond Poster
Joined: Dec 2013
Posts: 1,399
CA
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Thank you everyone for responding
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.
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#2099590 - 09/20/16 11:38 PM
Re: How many FTE will you add due to the HMDA Overhaul
JC (Darth HMDA)
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Diamond Poster
Joined: Dec 2013
Posts: 1,399
CA
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Got the final numbers on consumer lending today. Our LAR will grow from roughly 1700 entries to over 6100.... and that's a conservative estimate. Anyone by chance heard the CFPB change their mind about adding a grace period? haha
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.
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#2099603 - 09/21/16 12:33 PM
Re: How many FTE will you add due to the HMDA Overhaul
JC (Darth HMDA)
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Power Poster
Joined: Nov 2001
Posts: 7,983
FINALLY ABOVE the gnat line
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Yes, those "Tax-Ease" loans are gonna kill a few banks with new the HMDA data requirements. A lot of systems already have fields for these new underwriting fields - see what fields your system has and start collecting now. You will then have a little over a year to determine how accurate that info is and make corrections to culture, practice, procedures. You will also want to begin fair lending reviews based on this info in 2017 so management has time to fix any issues they may reveal. as of March 1, 2019 - your lending practices will be available for the world to see.
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"Once you learn to read, you will be forever free." - Frederick Douglass
My Opinion Only.
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#2099671 - 09/21/16 04:45 PM
Re: How many FTE will you add due to the HMDA Overhaul
JC (Darth HMDA)
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Diamond Poster
Joined: Dec 2013
Posts: 1,399
CA
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@ KayBee - that is what we're freaking out about! @Walden - Agree. It's scary that now anyone with excel, a little bit of knowledge, and your HMDA LAR can now run a full OLS Regression analysis of your portfolio. Well, at least it's job security.
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.
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#2099950 - 09/22/16 03:31 PM
Re: How many FTE will you add due to the HMDA Overhaul
JC (Darth HMDA)
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Diamond Poster
Joined: Jul 2007
Posts: 1,016
Pac NW
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0 75 mil Current: 8-10 Estimated: 0
Thanks HMDA Overhaul (until we need to begin reporting anyway)!
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#2100103 - 09/23/16 02:46 PM
Re: How many FTE will you add due to the HMDA Overhaul
JC (Darth HMDA)
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10K Club
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
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Yes, several of us will have more lines to report, and for many of already using technology, or will be, the technology will make this process less painful. Yes, data integrity will become even more important but the technology goes a long way in helping here too as long as what are in files correctly gets into, and remains, in our LOS'.
I feel Walden hit on the bigger point above, though, and we have to be thinking farther out and long term: what stories does the data now tell the bank and examiners that aren't readily identified currently. If you do not have the expertise or have the staff with the expertise to correctly analyze all of the new data points and how they can be used to work together and against you, who will you turn to do that for you? Is that where you hire a new analyst? Or is that where you bring in a firm to review for you? This potential increase in staffing to outsourcing costs needs to be considered as well.
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I don't repeat gossip, so listen closely...
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#2100116 - 09/23/16 03:37 PM
Re: How many FTE will you add due to the HMDA Overhaul
JC (Darth HMDA)
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Junior Member
Joined: Jul 2016
Posts: 31
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As of now, no new employees.
1.1 Billion 2015 LAR- 550 Estimated- 1000-1100
And not to hijack this thread, but curious as to where the HMDA function resides within your organization; business line or compliance. By that, I mean, who is responsible for the final scrub, consolidation and submission.
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#2100121 - 09/23/16 03:52 PM
Re: How many FTE will you add due to the HMDA Overhaul
Third Trip
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Platinum Poster
Joined: Aug 2015
Posts: 756
Land Lacking in Lakes, IL
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And not to hijack this thread, but curious as to where the HMDA function resides within your organization; business line or compliance. By that, I mean, who is responsible for the final scrub, consolidation and submission. I handle it here as the Compliance Officer (55M, 60 submissions/year). I'm enlisting help from another employee once the new stuff rolls out, and we'll probably end up purchasing some software. Right now I just do it in Excel.
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"Pressure is something you feel when you don't know what you're doing" - Peyton Manning
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