Kathleen Blanchard has over 32 years of experience in banking. She has developed lending and regulatory processes as a banker and consultant and presents detailed regulatory training that is very process specific. Her banking background includes commercial and private banking lending, credit review, credit policy and procedures, risk management and regulatory compliance at both community, regional and large international banks.
Kathleen has been providing training and consulting services for banks, credit unions and non-bank lenders on their regulatory compliance processes, HMDA and CRA reporting, process development and training since 2006. She is a Certified Regulatory Compliance Manager and a BOL Guru for BankersOnline.com. Kathleen presents her views and advice on HMDA and CRA and other regulatory matters at her website, www.kaybeescomplianceinsights.com
Since 2015, Kathleen has been delivering in depth regulatory compliance consulting and training via The HMDA Academy, a unique personalized combination of consulting, training and resources delivered online to assist financial institutions and vendors in learning and applying the revised HMDA process and rules going into effect in 2017 and 2018.
Areas of Expertise:
AML/BSA Independent Audits
A loan is secured by a rental dwelling owned by our borrowers. The dwelling is rented out for vacations and our borrowers do use it for personal vacation time, but never for more than 14 days in a year. We are having a disagreement whether this is HMDA reportable or not. If reported, what occupany code do we use?
A credit report and score was ordered but the report did not include a score. Should we report this as score and not a number?
Our financial institution originated the permanent financing to replace a construction loan for a new dwelling that was provided by another financial institution. Should we report this as a purchase, even though we did not make the construction loan?
Is an ADU a dwelling for HMDA purposes?
We have a loan secured by an older mobile home and another security by an older floating home. Are these dwellings for HMDA purposes?
A year end review revealed 6 errors on your LAR, must we resubmit?
My financial institution has decided to use the 6 items that mandate TRID disclosures to trigger an application for HMDA. Is this an acceptable definition:
Does an incomplete application for Regulation B mean an application is not HMDA reportable?
Should a written application be required for all business purpose applications, including those for HMDA reportable transactions?
A loan officer took an application for a dwelling secured but failed to ask what type of dwelling (site built, manufactured home, etc. Can we report NA for that field?