others have small changes that you should be
careful not to overlook. For those items that are
changing on some level, perform a thorough review
across business channels within your organization
and a gap analysis against policies, procedures,
data collection, and system edits and controls.
Have your policies and procedures around HMDA
data collection handy and re-familiarize yourself
with them so that you can ensure that you are
considering existing processes and how they might
change. Reading the actual rule also helps to ensure
that you understand the more nuanced reporting
requirements, such as the waterfall for reporting
AUS results, to ensure that you are asking the right
questions of your vendors, properly testing your
systems, and updating your policies and procedures
accurately. Don’t forget to also review any proposed
changes to the rule and those that become final.
From a technology systems and workflow
perspective, be sure to make note of what data is
currently collected and when. Don’t be too quick
to check the completion box if you are relying
upon existing fields and business rules for new
reporting criteria. For example, you likely already
collect age in the form of date of birth; however, the
revised HMDA rule requires reporting age as of the
application date. As a result, this will require you to
capture or calculate your borrower’s age at the time
of application. Also, date of birth currently may not
be a required field prior to final action if the loan
does not fund. This will require updates to business
rules within your loan origination system. Ensure
that you perform technology system due diligence
to ensure your capturing exactly what you need,
when you need it.
For reporting fields that are not changing, this is
still an opportunity to review what you are currently
reporting as well as your business lines and assess
them for accuracy. It is also a good idea to ask
questions of your vendor in terms of how existing
fields might be affected by their programming
efforts as this will impact your testing. For example,
Kathy Keller – (571) 918 1011
Newbold Advisors, LLC is not a law firm. Our advice is based our extensive professional experience of resolving complex issues for our mortgage industry clients.
Our Regulatory Compliance team can assist you to assess
the rule’s impact on your business, and then design and
build what you need to comply.
We will help you comply and ensure you are telling the
right story while also showing you how to turn the new
HMDA data into a competitive advantage!
Newbold is an experienced full service, mortgage-focused
consultancy who knows the business and can assist in
many ways across the entire mortgage value chain.
We stand ready to assist to ensure your HMDA
implementation is a success.
Newbold is Experience, Applied!
Is your data going to tell a story you don’t want to tell?
HMDA can’t wait.
Sending bad data to Washington is a terrible option.