HMDA reporters must follow the
new rules for covered loan applications when final action is taken on or after
January 1, 2018. While the focus of the changes has been on mortgages, there
are significant changes for other types of applications. The dwelling-secured
standard was generally adopted for closed-end loans and lines of credit for
consumers. Under the new rules, HELOC reporting is required, within threshold
limits. It’s imperative to know what information must be collected during a
Business or commercial loans have both the
loan-purpose test and the dwelling-secured test. How will data be collected?
What type of business-purpose loans will be reported? What factors are
considered in the purpose test? What if the collateral is a mixed-use property?
Will the current consumer application forms for HELOCs and the documentation for
commercial loan applications provide data for the new reporting requirements?
This must-attend webinar will address these questions and more!
- New CFPB HMDA implementation tool and data reference chart, released October
- Tips to use the HMDA Loan Scenarios tool from the CFPB for HELOC and
- Which consumer applications are covered loans that
require data collection at the time of application?
- What is the correct
- Identify the correct loan purpose – there are five options
and rules for multi-purpose loans
- How to properly request and record
demographic information and the process for applicants to “self-identify” under
subcategories for ethnicity and certain race categories
- Reg B changes
announced on September 20, 2017
- Which commercial applications are covered
loans that require data collection at the time of application? What types of
dwellings are included?
- What data will be reported or excluded for commercial
- Potential problem areas for both HELOCs and covered commercial
- Best practices for documenting that applications for
agricultural purpose are exempt
Susan Costonis, CRCM, Compliance Consulting & Training for FIs