HMDA 2018 (Correspondent)

Similar documents
HMDA 2018 IMPLEMENTATION PLANNING. HMDA Process Inventory

Home Mortgage Disclosure Act 2017, 2018, and Beyond. Presented by Marissa Blundell Bankers Advisory A CliftonLarsonAllen LLP Division

Summary of Reportable HMDA Data Regulatory Reference Chart a

Covered loans or applications if the property is

Consumer Financial Protection Bureau. March 15, Draft, Sensitive and Pre-Decisional Not for External Distribution

HMDA / Regulation C Amendments New 1003 Application

HMDA Regulations and New 1003 Application - Part 2

ICBA Summary of the Home Mortgage Disclosure Act (HMDA) Revisions to Regulation C

HMDA INPUT AND REQUIREMENTS. Updated: 3/16/2017, S. Noble

Revised HMDA Reporting Overview, Implementation and Planning March 2017

Instructional Reminder Regarding: Collection of Applicant s Ethnicity, Race and Sex on the Loan Application Demographic Information Addendum

Home Mortgage Disclosure Act HMDA Part 1. Presented by: Aaron Kouhoupt, Esq.

What do HMDA Rule Changes Mean for Covered Institutions?

CFPB Home Mortgage Disclosure Act (HMDA) Final Rule. Webinar August 4, 2016

Compliance Policy 2003-ALL

HMDA LET S GET IT RIGHT!

What s New in Mortgage Lending Compliance?

1) The credit union's assets total more than $44 million as of December 31, 2017,

Business Loan Application

S.2155 Implementation The Latest HMDA Changes

Credit history Bad credit history can discourage an individual s chances of being approved for a loan.

HMDA Filing Update. The webinar will begin at the top of the hour. You may download the presentation at:

Please stand by, the presentation will begin shortly. Your phones have been muted. If you re using the speakers on your PC you don t need to call in.

FFIEC HMDA Examiner Transaction Testing Guidelines 1

Q: Any discussion regarding tolerance violations with all the new additional fields?

Filing instructions guide for HMDA data collected in 2018

Fair Lending Risks and HMDA

The New CFPB HMDA Rules

HMDA: Haven or Havoc. Michigan Bankers Association. Compliance Services 2016 Temenos USA. All rights reserved.

Filing instructions guide for HMDA data collected in 2018

S (a) Impact Data. Unchanged Value 01 Record Identifier x 01 Legal Entity Identifier (LEI) 02 Legal Entity Identifier (LEI) x

2018 HMDA Implementation. Presented By: Karen Ruckle, Director of Compliance Bank of the Ozarks

HMDA FACT SHEET YOUR MAP TO REGULATORY CHANGE

HMDA: Haven or Havoc. Cindy Prince, Presenter December 5, 6 & 7, 2017 Assisted by Rachelle Dekker and Matt Goble

Home Mortgage Disclosure (Regulation C)

Wholesale and Correspondent Mortgage Partners Document and Disclosure Matrix

HMDA Update Nov. 13, Nov. 13, 2018 HMDA Update 1. Our Agenda Today

Implications and Risks of New HMDA Data Disclosure

HMDA Demographic Information Addendum Policy & Procedure

HMDA Workshop Part IV: Fair Lending & HMDA

HMDA Insights : Capitalizing on New Perspectives HMDA Adoption Costs: Did You Say $2 Billion?

Major Changes Looming for HMDA Reporting

CFPB HMDA Webinar Q&A May 24 and June 2, 2016 Sessions

2017 Interagency Fair Lending Hot Topics

Revised Uniform Residential Loan Application (URLA) Overview

CFPB Consumer Laws and Regulations

The New CFPB HMDA Rules What You Need to Know

To learn about navigation and other features of this e-learning course, click Help. Click Next to continue to the next page.

HMDA Road Trip: Get Directions Before Navigating the Expanded Data Fields, Including the GMI. October 4, 2017

Uniform Loan Delivery Dataset (ULDD) FAQs

Notice. Conducting a Fair Lending Self Assessment Britt Faircloth, CRCM 4/2/2018. April 2018 Florida Bankers Association

Comment Call (14-15) CFPB Home Mortgage Disclosure Act (HMDA)

Correspondent Lending Division Seller Partner Eligibility Policy

Fair Lending Compliance Basics: Class is in Session!

HMDA LAR Fields Effective 1/1/2018 Comparison with Current HMDA Fields - Updated 7/17/2016 Current Field New/Revised Field

Procedures for Withdrawing/Cancelling a Loan in Encompass For a loan that has been Approved by Underwriting (Updated 5/6/2016)

Filing instructions guide for HMDA data collected in 2019

The Ever Changing Landscape of Mortgage Lending. HMDA & The New URLA

Procedures for Denying Loans at the Branch Level (Updated )

New and Re-emerging Fair Lending Risks. Article by Austin Brown & Loretta Kirkwood October 2014

Table of Contents. Sample

Executive Summary of the 2018 HMDA Interpretive and Procedural Rule

Freehold Savings Bank, 68 West Main Street, Freehold, N.J Commercial Mortgage Construction Loan Term Loan Equipment Loan Line of Credit

Loan Growth and Compliance Pitfalls

Road Map To CFPB Compliance For The Auto Finance Industry

A Look at Tennessee Mortgage Activity: A one-state analysis of the Home Mortgage Disclosure Act (HMDA) Data

Final Rules and Effective Dates

Consumer Compliance Hot Topics

Fair Lending Internal Audits

Action Taken. PRE-APPLICATION Do you Prequalify? Do you have Preapprovals? Which road do you take? Be Consistent!

TABLE OF CONTENTS. .03 Farmers cooperatives. .01 A request made during the course of an examination

Home Mortgage Disclosure Act (HMDA) 2014 FIS and/or its subsidiaries. All Rights Reserved.

SMALL BUSINESS LOAN APPLICATION PACKAGE

Home Mortgage Disclosure Act. with Anne Lolley. / X4

Status of New Uniform Residential Loan Application and Collection of Expanded Home

Indirect Auto Lending Fair Lending Considerations

V. Lending HMDA. Home Mortgage Disclosure Act 1 V-9.1. Introduction. Applicability

With so much change, be sure to stay up to date!

HMDA: Haven or Havoc. Cindy Prince, Presenter December 5, 6 & 7, 2017 Assisted by Rachelle Dekker and Matt Goble

PROPERTY INFORMATION

Regulatory Change Management

BUSINESS LOAN APPLICATION

Section 1.35 Compliance Overview

FAIR SERVICING: REGULATORS WATCH FOR DISCRIMINATION BY SERVICERS

This is a PDF version of the 2019 Law survey. To complete the survey, follow this link to the online form.

Dakota County CDA Homebuyer Counseling Program Application

Washington, DC. HFA Performance Data Reporting- Borrower Characteristics

APPLICATION FOR HOUSING

HMDA: 2018 Changes & Data Analytics NOVEMBER 2, 2017

Today s Compliance Course ID # 7284

Procedure: Tracking Brokered Out Loans Date Issued: 04/01/2014 Date Effective: 04/01/2014 Date Revised: 07/12/2018

COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION

Partial Exemptions from the Requirements of the Home Mortgage Disclosure Act under

Presentation Topics. Changing Data Requirements Will Effect. Census data update and implications for CRA, HMDA and Fair Lending

Borrower SIGNATURE REQUIRED ONLY IF APPLYING FOR JOINT CREDIT Co-Borrower SIGNATURE REQUIRED ONLY IF APPLYING FOR JOINT CREDIT

Uniform Closing Data in Point Webinar Q&A

APPLICATION FOR CREDIT

CONSUMER CREDIT APPLICATION

New CFPB Mortgage Servicing Rules (Part 2): Loss Mitigation Procedures. John Rao Lisa Sitkin Josh Zinner

Action Taken. Boot Camp 360 Series Presented by Kimberly Lundquist

Transcription:

HMDA 2018 (Correspondent)

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. https://www.consumerfinance.gov/policy compliance/guidance/implementationguidance/hmda implementation/

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.

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, 2018. 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.

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).

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.

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.

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.

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.

Questions? Feel free to contact your Account Executive