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
We merged with another financial institution in 2017 and are confused about the reporting rules. There is an exclusion for loans acquired as part of a merger and acquisition yet there are instructions for how to report. What do we report?
As a HMDA reporter, can’t we ignore the demographic data collection required by Regulation B?
Our bank has a small staff that simply handles the HMDA LAR, testing all fields for all portfolios. They are confused by some terms that are new to them, such as ATR. What is HMDA talking about?
A large part of our HMDA LAR is made up of commercial loans. Do we just report NA for these new fields that borrow loan feature definitions from Regulation Z?
We have interest only lines of credit in our commercial portfolio. Will those be the ones we flag as having an interest only feature?
I am trying to obtain a good definition and/or guidance on how to report Revolving Lines of Credit that have been extended and not renewed for a particular year. Example – A customer has a revolving line of credit for $250,000 that originally was executed in November 2014 and is up for renewal in November 2015, however the borrower has asked for a 3-month extension which the bank granted, the amount and conditions are unchanged.
For 2015 reporting, can we/should we be reporting/treating the $250,000 as a renewal/extension that took place in 2015? Or not report it as it was an extension and not a renewal according to the CRA quidelines?
Do we complete the loans costs field and the points and fees field?
How will we report a ULI for a purchased loan that was originated before 1/1/2018?
How will we know if a purchased consumer loan was a cash out refinance or a plain refinance for HMDA loan purpose reporting?
Is it true that all business purpose loans and lines of credit will be HMDA reportable under the revised HMDA rule?