HMDA & Ag Properties
If your institution is subject to HMDA, the first thing you have to do when you receive a loan application is determine if it’s HMDA reportable. So, the first question to ask yourself is will the loan be dwelling-secured? If so, you can move on to the next question of whether the request is for a HMDA-reportable purpose [Purchase, Refinance, Improvement, or Other (aka Consumer-Purpose Home Equity)]. If so, it’s subject to HMDA, which means there are some things you need to request at the time of application to later report on your HMDA-LAR. But, you first need to understand what is and what is not considered a dwelling under the HMDA rules. There are some exceptions and, quite honestly, they don’t always make sense. One exclusion is for ag properties/farms.
David explains more in the video.
Published
2024/05/20
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.