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.

Mar 28

Mar 28 HMDA Application Date for Indirect Applications

Adam Witmer

HMDA

This HMDA video covers the requirements of the application date field for indirect applications.

Mar 25

Mar 25 HMDA App Date for Reinstated Applications

Adam Witmer

HMDA

This HMDA video focuses on the requirements of the application date field for a reinstated application.

Mar 24

Mar 24 Detached Structure Exemption for Flood Insurance

Adam Witmer

Flood

This video focuses on the requirements for using the detached structure exemption under flood insurance rules. Adam explains how to know if a structure can qualify for the exemption or not.

Mar 23

Mar 23 CRA Public File

Adam Witmer

CRA

This video talks about what must be included in a CRA public file including special requirements for HMDA reporters.

Mar 22
Mar 22 New Mortgage Servicing Rules and FAQs

Adam Witmer

Regulatory Update

Earlier this month, the CFPB issued a final rule that amends certain parts of the 2016 mortgage servicing rules relating to periodic statements. This rule revised the timing requirements for services that are transitioning between modified or unmodified periodic statements and coupon books when a consumer enters or exits bankruptcy. In addition to these rules, the CFPB

Mar 22
Mar 22 The Revised Loan Estimate

Adam Witmer

TRID

While most seem to fully understand the rules regarding the disclosure of an initial Loan Estimate, many seem to have a more difficult time understanding when a revised loan estimate is required. For example, I have heard the following questions asked many times:

Mar 22

Mar 22 Compliance Management Systems

Adam Witmer

Compliance Management

Adam talks about the core elements needed in a compliance management system including board of director oversight and the sub-elements of a compliance program. This video outlines the expectations of a CMS as outlined by the CFPB and other regulatory agencies. A sister article to this video can be found here.

Mar 21

Mar 21 Board Confidentiality of Suspicious Activity Reports

Adam Witmer

BSA

In this video, Adam talks about SAR confidentiality and how it applies to the bank and its directors. He even talks about how FinCEN sent a warning to directors and their attorneys reminding them of confidentiality of SARs.

Mar 14

Mar 14 Comparative Evidence of Disparate Treatment

Adam Witmer

Fair Lending

Adam discusses the second type of discrimination recognized by the courts: comparative evidence of disparate treatment. He gives examples and a warning to community banks and credit unions.

Mar 28
Mar 28 HMDA - Reporting End Loan as Home Improvement

Mar 28 HMDA Application Date for Indirect Applications

Mar 25 HMDA App Date for Reinstated Applications

Mar 24 Detached Structure Exemption for Flood Insurance

Mar 23 CRA Public File

Mar 22
Mar 22 New Mortgage Servicing Rules and FAQs

Mar 22
Mar 22 The Revised Loan Estimate

Mar 22 Compliance Management Systems

Mar 21 Board Confidentiality of Suspicious Activity Reports

Mar 14 Comparative Evidence of Disparate Treatment

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