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2019 HDMA data
In compliance with the current Regulation C, all credit unions, savings associations, banks, and for-profit non-depository mortgage lending institutions are urged to surrender specific Home Mortgage Disclosure Act data. It is required of them to do so if they meet the criteria set in place by this rule. What determines if a depository institution will be asked to disclose or report data publicly is the extent in which the loans or the institutions are federally related, its locality and that of its branches and the asset size. For the for-profit non-depository institutions its level of residential mortgage lending, the extent of how much business it undertakes in MSAs and the size and locality of its main and branch offices determine if they publicly disclose and report the 2019 HDMA data.
Amendments for 2019 HDMA data
The Bureau of Consumer Financial Protection made a few amendments for the 2015 rule to come up with the 2019 HDMA data that expands the amount of data collected and submitted by lenders. The new HDMA rule also alters the coverage requirements for reporting, transactions and the institutions.
The new rule has made the number of HDMA fields that should be reported on more. In the past, they were twenty-three, but the number has risen to forty-eight. Also, it has modified twenty of the already existing fields. Those that have been introduced include; interest rate, prepayment penalties, loan term, lender credits, discount points, points and fees, and credit score. It also consists of the borrower’s age and his/her credit score, application channel, combined loan-to-value (CLTV) ratio, non-amortizing loan features, Borrower-paid origination charges, and Mortgage loan originator NMLS identification.
It is necessary that all lenders collect all the new data that is required of them and report it by March 1, 2019, through the Consumer Financial Protection Bureau data reporting submission tool.
All the covered institutions are necessitated to report the information that they have collected and recorded for home purchase loan preapproval requests that are approved-but-not-accepted.
It is mandatory that from the start of 2020 all covered institutions that reported for more than 60,000 covered loans and applications combined in the past year will have to report the data four times in a year. The first submission of their reports is to be made on May 30, 2020.
One issue that remained unresolved is that of the sensitive financial information regarding consumers. The Consumer Financial Protection Bureau will determine if it is correct and if so how to disclose the data to the public. They will be able to do this through the use of a balancing test on the data collected on or after 2018 and submitted on or after 2019. The purpose of this test is that it will balance both the borrower and applicant privacy while still fulfilling the HMDA role. Recently, CFPB submitted a proposal explaining how the balancing test will be used and how the bureau will be able to conceal sensitive data.
2019 HMDA Data
The importance of these changes is that they help improve the data that is collected while at the same time modernize the way in which reports are made. For more information about 2019, HDMA data don’t hesitate to give us a call and send us a main and we will get back to you soon.
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