Be sure to JOIN US on April 16, 2020, for our webinar, “HMDA Data for Large Filers”.
HMDA compliance is tough! With all the data large filers are required to collect and report, there are bound to be mistakes. You can’t rest easy though because too many errors can lead to civil money penalties. This webinar will look at the data requirements for large filers and highlight some of the data fields that cause the most confusion. A couple of those confusing data fields include the “loan term” and the “introductory rate period”.
Click on the video to listen to Dave explain more.
Hi Dave Dickinson with Bankers Compliance Consulting. I want to talk HMDA and some of the quirky data fields that you have to deal with. Specifically, let’s talk about loan term, that’s data field number 82, and introductory rate period, data field number 83. Now small filers, you’re exempt. You don’t have to worry about this. But large filers, let’s get into the weeds. All right.
If it’s a loan, non-revolving credit, then you count loan term, not from origination to maturity but from first payment until maturity. So we close a loan today. You might have some odd days and then a full month. That first payment, from there until loan maturity, that is the loan term.
But wait, when it comes to revolving credit lines, you count from origination until maturity, not from the first payment. So origination and maturity for revolving credit. From first payment to maturity for non-revolving credit.
Easy enough, you say. Introductory rate, that’s field number 83. I don’t care if it’s a loan or a line, it’s from origination until the first change that can occur. Not from first payment but from origination until that first change can occur. That’s the kind of stuff you’ve got to get into the weeds if you’re a HMDA filer.
I hope this helps. Let us know if you have any questions when it comes to HMDA or any other regulatory compliance questions that we can help you with. Thanks for listening.
April 14th – Refinance, Modifications & Renewals
April 15th – COVID-19 Regulatory Update
April 16th – HMDA Data for Large Filers
April 23rd – HMDA Data for Small Filers
May 5 – Regulation B Joint Intent
May 7 – HMDA Demographic Information Collection
Published
2020/04/09
Dave Dickinson