In its December 2016 issue, the Mortgage Compliance Magazine published a collaborative article written by ADI President, Michael Mitchell, and Senior Consultants Rebecca Escario and Jonathon Neil. In this article, titled “Full Disclosure,” we shared our perspective on the challenges facing mortgage lenders in the short-run (i.e., 2016-18) and the long-run (i.e., 2019 and beyond) regarding reporting requirements under the Home Mortgage Disclosure Act (HMDA).
While much interest in the industry has focused on the New Rule published by the Consumer Finance Protection Bureau (CFPB), in our article we emphasize three main points concerning HMDA reporting for which we offer greater detail:
- HMDA reporters need to maintain attention on existing reporting requirements for 2016 through 2018 submissions;
- Lenders must be proactive in preparing their data for the new requirements when they go into effect in 2019; and
- There are important implications for Fair Lending compliance inherent in the new HMDA rule.
We invite you to review this article and share your comments and feedback with our team of compliance experts.