08/02/2004
When a mortgage is for a second residence, how would someone mark that on the HMDA Loan Application Register under the occupancy code?
06/21/2004
If a loan is denied, before a HOEPA test has even been done or considered, does a HOEPA test still have to be done for HMDA?
05/17/2004
HMDA requires an officer of a financial institution to certify the accuracy of the data. The regulation is silent on which officer should certify the accuracy. I believe this responsibility should reside with the Compliance Officer, not Internal Audit. Do you know of any announcements, etc., regarding this, or are you aware of what the "norm" is at other financial institutions?
01/05/2004
The HMDA Final Rules state that beginning in 2004 we will be required to report the lien status of applications and loans. In reviewing Appendix A to Part 203 -- Form and Instructions for Completion of HMDA Loan/Application Register [Effective as of January 1, 2004] I do not find a column on the new LAR for reporting the lien status, nor any instructions for reporting the lien status. Will this reporting information be added to the Loan/Application Register in the new FFIEC software?
11/01/2003
We are about to enter a period of reporting information on high cost loans on the HMDA LAR. The fun begins on January 1, 2004 - actually the first business day after that date.
09/16/2002
Bankers Compliance Consulting Real Estate Loan Matrix. I found on this web site indicates that a closed end home equity loan is not HMDA reportable. I would like to know the reason the author made that decision. I find the reg excludes open end lines of credit only...
08/12/2002
The new changes to Regulation C do not appear to be consistent with HMDA. In the near future we will be seeking both ethnic and race information. HMDA only makes reference to race, not to ethnicity. I do not think that collecting information the same as OMB is justification for an expansion of Reg C beyond that of HMDA. The regulators appear to have gone beyond HMDA. Applicants will be asked their ethnicity AND their race. Hispanics may have no problem with the first question, but how do they answer the next question about race? I think confusion and misclassification will result.Even the example LAR included in the new staff interpretation (page 56) shows a Hispanic couple and he is 'white' and she is 'black'. No direction about the categories have been offered. I do not know how to train the lending staff on these new rules. can anyone get a ruling from the FED about the differences between HMDA and Reg C?
03/29/2002
08/01/2001
07/01/2001
The Consumer Advisory Council ("CAC") met on June 28, 2001 to discuss current consumer concerns and give advice to the Federal Reserve Board.