HMDA: Occupancy Type
HMDA compliance can be a challenge. It takes a lot of time and training to ensure your data is accurate. While reporting the “occupancy” might seem pretty straightforward, the requirements for this field changed ever so slightly with the 2018 HMDA changes. And, as we see in our reviews, some habits can be hard to break.
David explains more in the video.
We go over to the occupancy. Pick up your pens and write this down. This is not owner occupancy; it's applicant occupancy. There's a difference. If I pledge my house for my kids to move out of the basement, my house is not theirs. They are going to buy their own place and were just using my house as collateral. Then the owner occupancy- no, the borrower occupancy. So my son and his wife are the borrowers. What's their occupancy of my place? They don't want them back, so it's not their primary residence. I don't want them back; it's not their secondary residence. Code three, you go, well, that says investment property. That's another as well. So if you have a non-borrower pledge or a third-party pledge, then you need to go with code three. So again, think about this as borrower or applicant occupancy. That's what the heading is. It's not owner occupancy.
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.