The revised HMDA reporting changes are imminent and although the changes roll out the next several years some of the changes have impact now. Your organization needs to have access to the complete data set for any applications that may have a last action taken date after January 1, 2018. If you do construction lending, that application may be in your pipeline now.
Your implementation effort should be well underway and consider all the implications, including policy, process, procedures, systems and communication/training. Given the expansion of the data to be reported, the ante has been upped on data accuracy and quality.
It may seem that the only areas affected are HMDA reporting and originations, it is important to be aware that the new HMDA reporting rule has impacts across the entire value chain.
Below is an example of considerations across the functions affected. It is by no means all-inclusive but rather a starting point.
Newbold has been actively engaging in the industry and with our clients to communicate the broad implications of the changes. Because of our unique position and strong knowledge of the mortgage industry, we can review your business model, quickly assess the impact of the HMDA rule and assist in integrating necessary changes into your operations. We stand ready to assist!
For your information, a recent article that Newbold authored for Mortgage Compliance Magazine can be found here.
Please contact us to learn more.