It seems like everywhere you look these days, somebody is talking about HMDA and the new rules. You may be wondering, "What's all the fuss about?" and you might even be thinking, "I've got plenty of time to worry about it." Am I right? While it is true that the majority of the requirements do not go into effect until 2018, there are eight months left to get your policy, procedures, and refined processes in place.
First, as you know, there is a new reporting threshold for 2017. If you did not originate at least 25 home purchase loans (including refinancing of home purchase loans) in both 2015 and 2016, you will not have to collect data in 2017 that would be reportable in 2018.
Second, while you will not be required to start collecting the new data until January 1, 2018, the Consumer Financial Protection Bureau (CFPB) has announced that those who wish to begin collecting the new ethnicity, race and gender information may do so without violating Regulation B. You would need to decide whether or not you will do so, and if you are, you need to nail down very clear procedures for collecting this new information.
And lastly, for those of you who rely on the Federal Financial Institutions Examination Council's software each year for reporting, while you will not use the CFPB's data submission tool until March 1, 2018, you need to begin preparing early. For those of you who rely on vendors, you will still need time to work with those vendors to ensure that everything is working properly. History has shown that any time the CFPB gets involved, things tend to get more confusing and complicated and reporting via electronic submission is not likely to be any different.
So, what do you need to do to get ready? Keep an eye out for a newsletter in the near future which will address putting together a plan of action to ensure that you are prepared!