Welcome to the Compliance Cohort. We are a group of compliance professionals working to make compliance easier. Our goal is to take complex compliance concepts and put them in simple terms that apply to the real world. We are glad you have found us and look forward to collaborating in the future.
If you haven't done so already, make sure you sign up for our free membership where you get access to many member-only videos, articles, and other resources.
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.
While logic would tell us that a definition should be consistent from one regulation to another, reality tells us that this is anything but the truth. When I teach compliance schools where we work through regulations from top to bottom, I always make an effort to point out the difference in the definition of “business day” as the definition varies - sometimes greatly - from one regulation to another. In fact, Regulation Z actually has two different definitions for business day: the precise definition and the general definition.
This HMDA video focuses on the loan purpose code for business purpose loans. Plus, Adam explains that there is one code you will never use for business purpose loans.
When the CFPB first inherited a number of regulations from the Federal Reserve over six years ago, they vowed to revisit those regulations. Eventually. Well, earlier today, the CFPB finally...
This HMDA video discusses the consistency requirements of the application date field on the HMDA LAR.
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.
This HMDA video covers the requirements of the application date field for indirect applications.
This HMDA video focuses on the requirements of the application date field for a reinstated application.
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.
This video talks about what must be included in a CRA public file including special requirements for HMDA reporters.
