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Critical HMDA Issues for HELOC Applications & Coverage Changes for Commercial Lenders, Effective January 1, 2018

HMDA reporters must follow the new rules for covered loan applications when final action is taken on or after January 1, 2018. It’s imperative to know what information must be collected during a HELOC application.

Dec 11, 2017 02:00 PM   -­­  Dec 11, 2017 03:30 PM
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Type of Event
On Demand Webinar

Who Should Attend
  • On Demand
  • Webinars
  • Lenders

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Description

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 HELOC application.

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!

Learning Objectives

  • New CFPB HMDA implementation tool and data reference chart, released October 16, 2017 
  • Tips to use the HMDA Loan Scenarios tool from the CFPB for HELOC and multi-family applications 
  • Which consumer applications are covered loans that require data collection at the time of application? 
  • What is the correct application date? 
  • 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 applications? 
  • Potential problem areas for both HELOCs and covered commercial loan applications 
  • Best practices for documenting that applications for agricultural purpose are exempt

Speaker

Susan Costonis, CRCM, Compliance Consulting & Training for FIs

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