HMDA Huddle – Q&As for Tackling the Intricacies of HMDA

Welcome back to ADI's quarterly Q&A series, HMDA Huddle. With the third quarter of 2022 ending and the end of the year approaching, it's critical to keep a strong focus on HMDA compliance. Lenders should continue to sharpen procedures and monitor the accuracy of all year-to-date LAR recordings. If you let this process slip earlier [...]

August 29th, 2022|

HMDA Huddle – Q&As for Tackling the Intricacies of HMDA

Welcome back to ADI's quarterly HMDA Q&A series, HMDA Huddle. As the end of the second quarter of 2022 approaches, HMDA compliance should remain a consistent focus. Many lenders loosen procedures and fall back into pitfalls of inaccuracy after their previous year's LAR is filed. Don't let that happen to your institution, as it will [...]

June 22nd, 2022|

HMDA Huddle – Q&As for Tackling the Intricacies of HMDA

Welcome to ADI's first issue of our quarterly HMDA Q&A series, HMDA Huddle. With another HMDA filing deadline behind us, lenders who successfully submitted their 2021 LAR can breathe a sigh of relief, and ADI is already looking ahead to 2022 reporting. ADI assists a wide variety of lender clients with HMDA LAR audit and [...]

March 29th, 2022|

4 HMDA Fields and the Key to Consistency

Guidance on the Home Mortgage Disclosure Act (HMDA) provides instructions for how lenders should report each Loan Application Register (LAR) field.  For most fields, the instruction is specific and leaves no room for differing interpretation or options for lenders to choose when reporting their LAR.  For a handful of LAR fields, however, there is some [...]

March 8th, 2022|

Four More Common HMDA Reporting Errors

Download This Article In two past Knowledge Center posts (Post 1 and Post 2), we discussed eight common errors that lenders encounter when satisfying reporting requirements under the Home Mortgage Disclosure Act (HMDA). The errors that we reviewed included: Failing to capture all HMDA-reportable transactions Reporting the incorrect loan amount Assigning the wrong geographies via [...]

October 12th, 2021|

CFPB Rescinds 2020 Policy Statements Issued Due to COVID-19

On March 31, 2021, the Consumer Financial Protection Bureau (CFPB) rescinded seven recent policy statements and one bulletin in an effort to ensure compliance with consumer protection laws and reinforce its supervisory and enforcement authority. These rescissions went into effect April 1, 2021. The policy statements were designed to provide flexibility to financial institutions that faced [...]

April 7th, 2021|

Aligning Fair Lending Testing with Why Consumers Withdraw their Mortgage Applications

Download This Article Withdrawn applications reflect an increasing proportion of non-approved first-lien mortgage applications as denials have become relatively less numerous. A decade ago, based on 2009 HMDA data, denials comprised just over one-half (53 percent) of non-approved first-lien applications. Denials fell to less than one-third (31 percent) of non-approvals a decade later. Over the [...]

February 18th, 2021|

Updated Census Bureau Data May Create New Compliance Risk for Lenders in 2022

Download This Article With the transition between presidential administrations, new regulations, and the ongoing effects from the pandemic and corresponding economic crisis, lenders are facing a dynamic environment in 2021 with respect to managing compliance risk under Fair Lending laws and the Community Reinvestment Act (CRA). There is another factor, however, receiving less attention but [...]

January 25th, 2021|

Lessons From the Recent Washington Federal Bank HMDA Settlement

Download This Article The recent settlement between Washington Federal Bank and the Consumer Finance Protection Bureau of reporting violations under the Home Mortgage Disclosure Act (HMDA) demonstrates that mortgage lenders should maintain a high level of focus on their compliance management system. In this article, we compare the bank’s earliest and most recent 2017 HMDA submissions to uncover the likely sources of [...]

January 12th, 2021|

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