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.
Before reading today’s question, make sure you’re all caught up in the series by reading part one, part two, part three and part four.
This is part five.
How are the LOS providers generating the ULI and on what document will it be placed?
Experts explained the Consumer Financial Protection Bureau released a specific algorithm to calculate the universal loan identifier. Several companies have begun announcing their systems with implement the new algorithm.
“The CFPB released a specific algorithm to calculate the ULI,” Scott Dunn, Wipro Gallagher Solutions head of product management, strategy and compliance, told HousingWire. “This algorithm has been implemented in the programming of Wipro Gallagher Solutions’ NetOxygen LOS System to include the Legal Entity Identifier, up to 23 additional letters/numbers and two-character check digit.”
“This ULI will follow the loan record from inception through servicing and can be placed on many documents, including the loan application,” Dunn said.
Another expert also announced their company will have a preparation tool that incorporates the new algorithm.
“Coming soon to ComplianceTech's software is a 2018 HMDA preparation tool which includes a Universal Loan Identifier generator,” the company told HousingWire.
One expert explained that whole origination vendors will calculate the ULI, but lenders using their own systems will need to ensure there is sufficient testing around their capability.
“The loan origination vendor provided systems that we typically work with are calculating the ULI using the LEI and check digits,” said Beji Varghese, Navigant Capital Advisors managing director. “These vendors support multiple LEI’s and make sure that the ULI’s are correctly calculated for new loans while storing and exporting ULI’s for previously generated loans.”
“Lenders with home grown systems need to ensure there is sufficient testing around their capability to generate ULI’s and store ULI’s for purchased loans,” Varghese told HousingWire.
Check back Wednesday to read part four of this series as we count down until the end of 2017.
