HMDA Preapprovals

It’s quite common for financial institutions to use the terms “prequalification” and “preapproval” differently and even interchangeably. Often, realtors and others in the mortgage industry, define these differently as well too. If you are a HMDA bank; however, you need to be crystal clear what each of these terms mean based on HMDA’s definition. Why? Prequalifications are not HMDA reportable while preapprovals are. If you mix these up, you are bound to have errors on your HMDA LAR, which could require you to resubmit your data.

David explains more in the video.


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Video Highlights:

  • There is a big difference between prequalifications and preapprovals where HMDA is concerned.
  • Whether you have a preapproval program or not is based on very specific criteria.
  • Confusion can arise if you do occasional ad hoc preapprovals vs. having a preapproval program. This should be clarified with your field examiners to be sure.

Published
2023/05/25

 
David Dickinson

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.

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