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.