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HMDA Roadmap Part 2: Operations Systems, Audit & Reporting Implications

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Wednesday, October 5, 2016

12:00 pm – 1:30 pm PT
1:00 pm – 2:30 pm MT
2:00 pm – 3:30 pm CT
3:00 pm – 4:30 pm ET

Only five of the current HMDA fields will remain unchanged – dozens will be added!

The CFPB’s final HMDA rule made sweeping rules changes that become effective in 2018. Why worry now? All dwelling-secured, consumer-purpose loan applications, both closed and open end, will be reported with final action dates after January 1, 2018. Dwelling-secured, business-purpose loans will continue to be reported if they are for acquisition, improvement, or refinance, but business-purpose, open-end lines for those purposes will also be reported. This is a significant change to commercial lending – along with the expanded fields. Regulators are allowing a long implementation window because the changes are complex and will require extensive processing and system changes.

Part 2 of this two-part series will provide a road map for operations, data systems, and audit scope, including the implications of reporting dozens of new data fields. Only five of the current HMDA fields will remain unchanged. More data means more potential errors, increased monitoring/review, and greater fair lending scrutiny. You’ll learn practical tips for developing a strong project plan and working effectively with operations and audit staff as well as vendors that develop software and data-gathering tools.

Continuing Education: Attendance verification for CE credits upon request

HIGHLIGHTS

  • Tips to prepare for five potential surprises in the new rules:
    1. What resources are needed?       Key questions about management support, staffing, technology, and impact of operational changes.
    2. What are the key changes in data reporting and analysis? Surprises may include applications that begin in one year but final action occurs in the next year, and potential disconnects when regulators compare different years of data.
    3. What are concerns about operational process decisions? Loan decisions may be made differently for in-house loans than for secondary market loans that use Automated Underwriting Systems (AUS).
    4. Who are the new players? New lines of business will be reported for home equity lines and commercial lending lines for covered purposes. These changes will require revised audit procedures.
    5. What happens next? Expanded data fields will increase fair lending risks and require enhanced analysis. Closer scrutiny by regulators to confirm data integrity will require additional monitoring procedures and resources.
  • Reporting challenges for the self-identified race and ethnicity fields and tips for operational monitoring
  • Auditing problem areas such as reporting denial reasons, correct income, property types, and more
  • Five strategy steps to prepare for the changes:
    1. Highlights of the original rule and hot buttons in operations, audit, and reporting
    2. Current technology review
    3. Compare current data to modified fields and develop a matrix to identify system limitations
    4. Review CFPB resources, like the resources posted on July 18, 2016, that include filing instructions for HMDA data collected in 2018; learn about Filing Instruction Guide (FIG)
    5. Develop a plan for additional training, policy and procedure changes, and project plan assignments

  • TAKE-AWAY TOOLKIT
    • HMDA key dates timeline and coverage charts
    • HMDA worksheets and flowchart
    • Road map template for an implementation plan
    • Employee training log
    • Quiz you can administer to measure staff learning and a separate answer key

DON’T MISS THIS RELATED WEBINAR!

"HMDA Roadmap Part 1:
Impact, Important Changes & Implementation Considerations for Lenders "

on Friday, September 9, 2016
If you missed it, you can order a recording of the live webinar, with a free digital download.

WHO SHOULD ATTEND?

This informative session is designed for lenders, personal bankers, loan assistants and processors, loan operations staff, compliance officers, fair lending officers, and auditors.

PLEASE NOTE:    Webinar content is subject to copyright and intended for your individual financial institution’s use only.