Bio:
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
Compliance Audits
Compliance Consulting
Compliance Review
CRA
HMDA Analysis
Questions Answered
10/01/2023
A counteroffer was made, the borrower accepted the counteroffer, and the loan moved forward to closing, but the borrower did not sign the documents at closing and the loan was not originated. Should this application be reported with the original requested values as an Approved Not Accepted, or should we report the counteroffer values as a Denial?
09/24/2023
A consumer purpose loan was originated to consolidate the borrower's credit card debt. The loan is secured by the principal dwelling of the borrower's parents. The parents are not borrowers on the loan and the borrower is not on the deed to the property. What is the occupancy type for this loan?
09/24/2023
For a true preapproval with a final action of "Preapproval Approved Not Accepted" is a rate spread reported, or is NA reported? These loans do not have a property address and would not have received a Loan Estimate.
09/17/2023
We are considering originating assumption loans. Our interpretation is that assumptions are indeed HMDA reportable. However, we cannot locate any specific identifiers within the HMDA reporting database that specifically classifies the transaction as an assumption. Can you provide further guidance? These would be on transactions where indeed there is a new borrower versus those where they are removing an individual due to death, divorce, separation, etc.
09/17/2023
A loan was originated to purchase a subdivision lot. The borrower plans to apply for a construction loan in the next two years in order to build a new home. Does this plan for a construction loan make this lot loan reportable for HMDA?
09/10/2023
A loan was originated that began with an individual borrower but closed in the name of an entity. We initially collected GMI on the individual and reported it as such. Is this acceptable for HMDA?
09/10/2023
For loans to entities (LLC, Corporation, Trust, etc), if the lender calculated a DTI (along with a DSC - debt service coverage ratio), do we report the DTI for HMDA?
09/03/2023
Is a consumer loan secured by a non-owner occupied rental dwelling considered business purpose due to the collateral?
10/16/2022
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?
10/09/2022
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?
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