$219 fee with a credit card. Once payment is
processed, the LEI will be issued in 3 to 5 business
days. Do not forget to add the annual renewal of
your LEI to your list of compliance due dates. It
will expire one year after it is issued if you do not
renew it. While we are talking about the ULI, it is
important for you to determine how your ULI will
be created. If your LOS vendor will not be creating
the ULI, then your HMDA processing vendor will
need to or vice versa.
Your HMDA LAR for 2018 and beyond will
contain more consumer data than ever before.
To help ensure compliance with GLBA and
requirements to ensure that non-public personal
information is properly safeguarded, it is time to reevaluate your authority and access controls around
your report. For example, who has authority to
generate your HMDA LAR and who has access to
the report where it is retained?
And then there is training. You should absolutely
start early with your announcements, communications,
So there you have it. I hope I’ve given you
some ideas to help you develop your HMDA
implementation roadmap. Of course, I have only
scratched the surface of the various steps you will
need to take but, at minimum, I hope that this has
given you some ideas to ponder and provoked
thought into areas you had not previously considered.
Lisa Klika is chief compliance officer at Guild
Mortgage. She can be reached at LKlika@