Preparing to Submit Your 2022 HMDA Data

Getting ready to submit your HMDA Data by March 1st of each year can be a little daunting as there is very little room for error. One area that can trip you up, especially if you are new to HMDA, is preapprovals. Loan officers often use the terms “prequalification” and “preapproval” interchangeably, but HMDA clearly distinguishes the two. Prequalifications are not reported, while preapprovals are if you have a “preapproval program.” Getting these mixed up can really mess up your data.

David explains more in the video.

 

HMDA Resources!

Transcript: 

All right. Page 23, pre-approvals. I told you there are two full pages. Look at the letter C with me. There has to be a program, first off. Number two, there must be a comprehensive analysis with a written commitment for a designated period to offer a specific dollar amount to purchase a home. That all has to be met. The key to me there is the last part of that, which talks about full verification as typically done by the institution's part of its normal credit evaluation program.

In other words, you're completely checking them out. You don't have a property yet, but you're underwriting the people. That is a pre-approval if it's a program. And they don't define a program, but on page 24, it talks about whether you call it a pre-approval really doesn't matter. If you're doing this on a regular basis, you have a program. Letter E talks about ad hoc, meaning you do it once in a while. Part of this problem is, what do you mean by ad hoc? What's once in a while? What's a program? There is no definition for this. So if you have any questions about that, that's something you really need to take up with your regulators to find out. I've had a couple of clients that thought they didn't have a program, and the regulators ruled they did. Or the other way around. You really want to nail this and ensure you understand clearly.

#HMDA FDIC
#HMDA CFPB

Published
2022/12/15

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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