All in HMDA

HMDA Loan Purpose Hierarchy

In this extended Compliance Clip (about 8 minutes), Adam discusses the new purpose hierarchy in this HMDA video and explains why the CFPB changed the long-standing order of which purposes take priority over other purposes.   This video dives into the rule, commentary, and preamble to give us a full understanding of the new HMDA hierarchy.

With the recent changes to the Home Mortgage Disclosure Act (HMDA) which became effective on January 1, 2018, many compliance professionals have had to rethink how they report certain loan situations for HMDA purposes.  Particularly, there have been some logistical challenges in the way certain Home Improvement loans are reported.

The FFIEC has finally released an updated HMDA Getting It Right Guide.  The FFIEC release the new guide today, which is the first revision of the guide since 2013.  The new version has been completely revised to reflect the HMDA changes from the 2015 final rule as well as the 2017 amendments that went into effect on January 1, 2018.  

he HMDA mixed-use property test has slightly changed with the new 2018 rules.  Some of what we knew before still applies, but there are definitely some new difference.  Specifically, the mixed-use property test is now a two step process where you must first look at the primary use of a property and then make sure the loan does not have a purpose of home improvement.  First, you must determine if...