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#2099269 - 09/19/16 09:40 PM How many FTE will you add due to the HMDA Overhaul
JC (Darth HMDA) Offline
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JC (Darth HMDA)
Joined: Dec 2013
Posts: 1,399
CA
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
How many FTE will you be adding due to the changes to HMDA
single choice


Votes accepted starting: 09/19/16 09:36 PM
You must vote before you can view the results of this poll.
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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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#2099296 - 09/20/16 12:17 AM Re: How many FTE will you add due to the HMDA Overhaul JC (Darth HMDA)
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
You should add "0" to the poll.
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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)
TMatt87 Online
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TMatt87
Joined: May 2011
Posts: 1,984
Idaho
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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#2099359 - 09/20/16 03:00 PM Re: How many FTE will you add due to the HMDA Overhaul JC (Darth HMDA)
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
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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#2099367 - 09/20/16 03:31 PM Re: How many FTE will you add due to the HMDA Overhaul David Dickinson
JC (Darth HMDA) Offline
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JC (Darth HMDA)
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Posts: 1,399
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Originally Posted By David Dickinson
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)
JC (Darth HMDA) Offline
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JC (Darth HMDA)
Joined: Dec 2013
Posts: 1,399
CA
It wont let me edit the post. Sorry!
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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)
raitchjay Online
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Joined: Oct 2009
Posts: 9,088
OK
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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#2099376 - 09/20/16 03:42 PM Re: How many FTE will you add due to the HMDA Overhaul JC (Darth HMDA)
Truffle Royale Offline

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Posts: 17,395
0 new hires but I'm going to cross-train a closer to help with HMDA.
Asset size 2B
Current LAR 2000
Estimated 2018 ?? (could be double this year's)

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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)
raitchjay Online
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Posts: 9,088
OK
Nevermind....full-time employees..ok.
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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)
raitchjay Online
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Joined: Oct 2009
Posts: 9,088
OK
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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#2099384 - 09/20/16 03:51 PM Re: How many FTE will you add due to the HMDA Overhaul JC (Darth HMDA)
DeeGail Offline
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Joined: Apr 2015
Posts: 8
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)
#Just Jay Offline
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#Just Jay
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
0

300 mil
Current: 1000
Estimated: 1100
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#2099480 - 09/20/16 06:45 PM Re: How many FTE will you add due to the HMDA Overhaul raitchjay
renniks Offline
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renniks
Joined: Sep 2003
Posts: 2,162
New England
raitchjay, FTE = Full Time Equivalent, in other words, 1 employee at 8 hours, 2 employees at 4 hours each = 2 FTE

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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)
JC (Darth HMDA) Offline
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JC (Darth HMDA)
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Posts: 1,399
CA
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)
JC (Darth HMDA) Offline
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JC (Darth HMDA)
Joined: Dec 2013
Posts: 1,399
CA
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 smile
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#2099592 - 09/20/16 11:57 PM Re: How many FTE will you add due to the HMDA Overhaul JC (Darth HMDA)
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,293
Oh my! I guess any institutions with large HELOC portfolios will see significant growth, as well as any that had a lot of non-reportable dwelling secured consumer purpose loans.
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HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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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)
waldensouth Offline
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waldensouth
Joined: Nov 2001
Posts: 7,983
FINALLY ABOVE the gnat line
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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#2099671 - 09/21/16 04:45 PM Re: How many FTE will you add due to the HMDA Overhaul JC (Darth HMDA)
JC (Darth HMDA) Offline
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JC (Darth HMDA)
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Posts: 1,399
CA
@ KayBee - that is what we're freaking out about! smile

@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. smile
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#2099676 - 09/21/16 04:56 PM Re: How many FTE will you add due to the HMDA Overhaul waldensouth
Kathleen O. Blanchard Offline

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Originally Posted By waldensouth
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.


Agreed. Re data being collected now in your LOS, make sure it is accurate, as said above, and make sure - if that data will be used for HMDA in 2018 - that it is the data the HMDA is requesting. Is it the score you relied upon, is it the LTV and value that you relied upon. That can be tricky!
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2099682 - 09/21/16 05:04 PM Re: How many FTE will you add due to the HMDA Overhaul raitchjay
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,293
Originally Posted By raitchjay
Nevermind....full-time employees..ok.


FTE usually means full time equivalent (1 full time, or 2 part (1/2) time) for example.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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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)
fmissle Online
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Joined: Jul 2007
Posts: 1,016
Pac NW
0
75 mil
Current: 8-10
Estimated: 0

Thanks HMDA Overhaul (until we need to begin reporting anyway)!

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#2100090 - 09/23/16 02:02 PM Re: How many FTE will you add due to the HMDA Overhaul JC (Darth HMDA)
JSD Offline
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JSD
Joined: Oct 2000
Posts: 512
USA
Zero new employees
221.9 Billion
2015 LAR = almost 132,000
Estimate increase of reportable loans (LOCs) = 51,000+

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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)
#Just Jay Offline
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#Just Jay
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
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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#2100116 - 09/23/16 03:37 PM Re: How many FTE will you add due to the HMDA Overhaul JC (Darth HMDA)
Third Trip Offline
Junior Member
Joined: Jul 2016
Posts: 31
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
MScarn6942 Offline
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Joined: Aug 2015
Posts: 756
Land Lacking in Lakes, IL
Originally Posted By Third Trip
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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