Auditing HMDA: What’s a HMDA Application?.
When do you have an application for credit? That may seem like a fairly simple question but in reality, it’s not. That’s because there is no one universal definition of an “application” for compliance purposes. You have to look at each regulation, how it defines an application and proceed accordingly. While many financial institutions try, you just can’t simplify it. For example, in a typical mortgage transaction, Regulation B, HMDA and TRID could all come into play, and all three have different definitions as to what constitutes an application. Receipt of an application triggers certain compliance requirements and if you use the TRID definition for Regulation B requirements or the HMDA definition for the TRID requirements it will likely result in violations.
David explains more in the video.
Published
2024/10/21
David Dickinson
David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.
He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.
David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.