HMDA 2018 (Correspondent)

Transcription

1 HMDA 2018 (Correspondent)

2 Legal Disclaimer The materials and information provided during this presentation is limited to the discussion of PRMG s policies with respect to the amended Home Mortgage Disclosure Act and Regulation C and does not constitute legal advice. You are strongly encouraged to reach out to your legal and compliance department, consultants and/or attorneys to ensure your practices, policies and procedures meet federal and state legal requirements. This webinar may not be copied, recorded, or redistributed in any form. For more information regarding the Consumer Financial Protection Bureau s (CFPB) Home Mortgage Disclosure Act, please refer to the CFPB s implementation page, which provides a number of resources. compliance/guidance/implementationguidance/hmda implementation/

3 Who Reports HMDA? PRMG has an obligation to report transactions for both Delegated and Non Delegated Correspondent channels. However, the way we report these two types of transactions differ. We must report all final decisions the same way in non delegated as we do in wholesale because PRMG is making the credit decision prior to closing. As such, we report all funded loans as originated by PRMG for the purposes of HMDA, even though the loan closes in the non delegated correspondent s name. There is no need for the non delegated client to report these transactions. We DO NOT report denials or originations for the Delegated Correspondent Channel. We only report the loans we purchase from the Delegated Correspondent. The Delegated Correspondent is responsible for reporting final decisions. Funded loans will be reported as originated by the Delegated Correspondent for HMDA purposes.

4 Important Changes! Home Mortgage Disclosure Act (HMDA) will require additional data points that must be reported with our 2018 HMDA submission to the Consumer Financial Protection Bureau (CFPB). Any application taken on or after January 1 st, 2018, must include a more detailed collection of the applicant(s) demographic information, that must be taken on a new DEMOGRAPHIC INFORMATION ADDENDUM. Correspondents will have to provide PRMG the more inclusive Demographic Information on applications dated on or after January 1 st, Loans with applications dated prior to January 1 st, 2018 and funded, denied, or withdrawn (i.e. final decision) on or after January 1 st, 2018 will contain the additional data points in our March 1 st, 2019 HMDA submission with the exception of the additional demographic information.

5 Universal Loan Identifier (ULI)? For Non Delegated Correspondent, PRMG will be using our own generated ULI on loans that we purchase or otherwise make a final disposition on in 2018, forward. For Delegated Correspondent, PRMG must receive the ULI from the Delegated Correspondent upon loan purchase as this will be a new required field. In order for a Correspondent to generate a ULI out of their system, they must obtain a Legal Entity Identifier (LEI).

6 Key Highlights in FT360 For Demographic Information When you mark an application was taken Face to Face, you must enter the Demographic Information. On a Face to Face Application, if an applicant wishes to not provide you their race, gender, or ethnicity you must make an educated/reasonable determination based on visual observation or surname (i.e. name). The system will now REQUIRE you on a Face to Face application to mark for each (Ethnicity, Race and Gender), yes or no, whether you made the determination based on Visual Observation or Surname.

7 Key Highlights in FT360 For Demographic Information REMEMBER: If an applicant chooses I do not wish to provide this Information, You MUST leave that box marked but ALSO PROVIDE the additional Ethnicity and Race information based on Visual Observation or Surname if the application was taken Face to Face. If the application was not taken Face to Face then it is ok to only have I do not wish to provide this information.

8 New Documents in FT360 Some systems like FT360 will show a red X through the government monitoring section on page 3 of the loan application. For applications taken January 1 st, 2018 or after, the demographic information will go on the Demographic Information Addendum because the government monitoring section does not have all the required fields.

9 New Information Addendum To your right is a sample of a Demographic Information Addendum. PRMG will require this form for all applications taken on or after January 1 st, 2018.

10 Questions? Feel free to contact your Account Executive