The Home Mortgage Disclosure Act deadline looms closer, but many questions still remain unanswered.
To combat this, HousingWire set to work to bring readers answers to the most asked questions as we countdown to the end of the year.
Most of the 2015 updates to HMDA take effect in January 2018.
Back in November, HousingWire hosted a webinar on HMDA, where panelists stressed the importance of preparing for the upcoming HMDA reporting requirements.
But due to an overwhelming demand, we are now presenting HousingWire readers with a 10-part series, each answering one of the most popular questions when it comes to HMDA.
To make sure you’re caught up, check out part one to see the answer to the first question.
This is part two.
Do the HMDA changes lay the foundation for a new reporting system to be in place by January 2020? If so, what does this process look like?
In short, yes.
One expert explained the new reporting standards will require updated systems and increased storage space.
“Since the HMDA Rule requires new quarterly reporting for large volume lenders in 2020, many institutions are preparing now to satisfy the requirement,” said Rose Bogan, Digital Risk senior vice president of governance risk and compliance. “Although, the first quarterly submission will be due by May 30, 2020, there is no surprise with the increase in data points, it will require updated systems and increased storage space.”
“Institutions should already be auditing their systems to determine if their existing IT infrastructure on collecting and reporting data will be sufficient or if new, updated systems will be required,” Bogan told HousingWire. “Lenders should also be sure that their servicing departments and those companies they utilize to service loans are aware of and in compliance with HMDA collection and reporting practices.”
Another expert, Scott Dunn, Wipro Gallagher Solutions head of product management, strategy and compliance, told HousingWire the current HMDA implementation does lay some foundation for the new reporting stem that will need to be in place by January 2020.
Here are some of the foundations he listed:
- The pipe delimited format is already in place.
- The electronic submission is already in place.
- The automation enabled today, with the exception of three data points, offers the opportunity for less adaptation down the road, in the event additional changes are forthcoming from the CFPB.
- The fact that we have given voluntary reporting capability to the collection of open-end transactions today has already set the foundation to collect this data when the volume threshold is met and must begin reporting by January 2020.
Be on the lookout for part three coming this Friday.
Consider yourself a HMDA expert and want in on the conversation? Email me: kramirez@housingwire.com.
