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On March 31, 2021, the Consumer Financial Protection Bureau (CFPB) rescinded seven recent policy statements and one bulletin in an effort to ensure compliance with consumer protection laws and reinforce its supervisory and enforcement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Download This Article Withdrawn applications reflect an increasing proportion of non-approved first-lien mortgage applications as denials have become relatively less numerous.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|

CFPB Fines Washington Federal $200,000 for HMDA Errors

Washington Federal Bank, N.A., already under a 2013 consent order addressing violations of Home Mortgage Disclosure Act (HMDA) reporting requirements, must pay a $200,000 civil money penalty and beef up its compliance management related to later violations under a consent order announced October 27th by the Consumer Financial Protection Bureau (CFPB). In the new consent [...]

November 10th, 2020|

CFPB Releases Updated Report on New and Revised HMDA Data Points for 2019

On August 27, 2020, the Consumer Financial Protection Bureau (CFPB) released its second report on the publicly released data submitted under the Home Mortgage Disclosure Act (HMDA) for 2019 mortgage lending activity. The new report provides an updated review of new and revised HMDA data points that were mandated for HMDA reporting in the CFPB’s [...]

August 28th, 2020|