Small-reporter HMDA: Wait and see
07/15/2018
How should we report if a loan is a single-family property, or has 2 to 4 units, or is a multifamily property?
You can reach Kathleen via email at kblanchard@keycomplianceservices.com,
07/15/2018
How should we report if a loan is a single-family property, or has 2 to 4 units, or is a multifamily property?
07/08/2018
As a small reporter, will we start to report our home improvement loans that are not dwelling secured as we did prior to January 1, 2018?
07/01/2018
What types of applications are counted to determine if a financial institution meets the reporting thresholds?
06/24/2018
Can we stop completing the new fields immediately? Senior management is asking if we can just stop now.
06/17/2018
Our institution is a "small reporter" under the revised HMDA rule. Should we cancel our Legal Entity Identifier?
03/04/2018
1026.34 cites a prohibition on structuring loans to evade requirements. Would this include reducing the interest rate on a loan to avoid HOEPA? If we can do this, are there any fair lending or UDAAP considerations?
01/07/2018
Why do our commercial lenders have to obtain an NMLSR ID number just for HMDA reporting? This is a real burden on financial institutions.
12/31/2017
I don’t understand how to report the revised HOEPA field. Two of the choices include that the loan is “covered” by HOEPA.
12/24/2017
Our institution made the credit decision on a loan purchased from a correspondent, but we did not receive the application directly from the applicant and the note is in the correspondent’s name. How can we report a loan as originated and say the application and first payment relate to the other institution?
12/17/2017
How can a loan purpose be not applicable for HMDA? Loan purpose has always been a way to determine if a transaction is covered by HMDA.