Mortgage Compliance

MBA to the Rescue; HMDA Extension Requested

Just in case you haven’t been following things closely, lenders will be required to report a whole bunch of additional HMDA information for loans reported in 2018; but you probably already knew that (I hope). The MBA, in support of its members and the industry, says that CFPB should extend the new requirements for at least one year because CFPB hasn’t lived up to end of the bargain. According to the MBA request, lenders and industry vendors are still awaiting for the following from CFPB: · A release of the new reporting portal · A promised geocoding tool for use by lenders in identifying property locations · New data validation information · Information of the security of consumer PII reported under HMDA There is no reason to rush to implement the desired CFPB changes. The current HMDA data reporting provides sufficient information for lending review and evaluation, as it has done for years. Why push to implement new requirements when everything isn’t in place to allow lenders to properly prepare for compliance? In addition, such a delay will allow additional time for a more detailed review to determine if all of the new required data elements would be beneficial. Further, if CFPB has the requisite authority to make such changes. For more information and insight, you can review MBA’s information and their letter. I, for one, agree. Why rush things when we’re not ready? We would hate to go through all the time and expense to prepare for things as they are currently presented, only to be required to make additional costly changes for adjustments made after the fact. Hopefully, rational thinking will prevail (for a change).
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Just in case you haven’t been following things closely, lenders will be required to report a whole bunch of additional HMDA information for loans reported in 2018; but you probably already knew that (I hope). The MBA, in support of its members and the industry, says that CFPB should extend the new requirements for at least one year because CFPB hasn’t lived up to end of the bargain. According to the MBA request, lenders and industry vendors are still awaiting for the following from CFPB: · A release of the new reporting portal · A promised geocoding tool for use by lenders in identifying property locations · New data validation information · Information of the security of consumer PII reported under HMDA There is no reason to rush to implement the desired CFPB changes. The current HMDA data reporting provides sufficient information for lending review and evaluation, as it has done for years. Why push to implement new requirements when everything isn’t in place to allow lenders to properly prepare for compliance? In addition, such a delay will allow additional time for a more detailed review to determine if all of the new required data elements would be beneficial. Further, if CFPB has the requisite authority to make such changes. For more information and insight, you can review MBA’s information and their letter. I, for one, agree. Why rush things when we’re not ready? We would hate to go through all the time and expense to prepare for things as they are currently presented, only to be required to make additional costly changes for adjustments made after the fact. Hopefully, rational thinking will prevail (for a change).Just in case you haven’t been following things closely, lenders will be required to report a whole bunch of additional HMDA information for loans reported in 2018; but you probably already knew that (I hope).

The MBA, in support of its members and the industry, says that CFPB should extend the new requirements for at least one year because CFPB hasn’t lived up to end of the bargain.

According to the MBA request, lenders and industry vendors are still awaiting for the following from CFPB:

  • A release of the new reporting portal
  • A promised geocoding tool for use by lenders in identifying property locations
  • New data validation information
  • Information on the security of consumer PII reported under HMDA

There is no reason to rush to implement the desired CFPB changes. The current HMDA data reporting provides sufficient information for lending review and evaluation, as it has done for years.

Why push to implement new requirements when everything isn’t in place to allow lenders to properly prepare for compliance?

In addition, such a delay will allow additional time for a more detailed review to determine if all of the new required data elements would be beneficial. Further, if CFPB has the requisite authority to make such changes.

For more information and insight, you can review MBA’s information and their letter.

I, for one, agree. Why rush things when we’re not ready?

We would hate to go through all the time and expense to prepare for things as they are currently presented, only to be required to make additional costly changes for adjustments made after the fact.  Hopefully, rational thinking will prevail (for a change).

Michael Vitali

About the Author

Michael Vitali

Michael L. Vitali – Independent Consultant to the Mortgage Industry Mike Vitali is an independent consultant to the mortgage industry on matters concerning compliance and mortgage lending. He most recently served as the Senior Vice President and Chief Compliance Officer for LoanLogics, monitoring regulatory developments and their practical implications for the mortgage lending industry. His duties included research, interpretation, and analysis of existing and proposed legislation related to the industry in support of recommendations for policy and/or procedure changes to maintain continued quality and compliance with all applicable laws, rules and regulations, investor requirements, and standard mortgage practices. In his more than 40 years in the mortgage industry, in senior level management, he has gained experience in all areas of mortgage lending, risk management, and compliance. Mike is a past President of the MBA of Greater Philadelphia, is a charter member and was the second Chairman of the MBA of Pennsylvania, and a past board member and Legislative Chair of both associations. He is a recipient of the 1998 Mortgage Banker of the Year Award from the MBA of Greater Philadelphia, and the 2003 Chairman's Award from the MBA of PA, and currently serves on several compliance related task forces for MBA.
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Michael Vitali

About Michael Vitali

Michael L. Vitali – Independent Consultant to the Mortgage Industry Mike Vitali is an independent consultant to the mortgage industry on matters concerning compliance and mortgage lending. He most recently served as the Senior Vice President and Chief Compliance Officer for LoanLogics, monitoring regulatory developments and their practical implications for the mortgage lending industry. His duties included research, interpretation, and analysis of existing and proposed legislation related to the industry in support of recommendations for policy and/or procedure changes to maintain continued quality and compliance with all applicable laws, rules and regulations, investor requirements, and standard mortgage practices. In his more than 40 years in the mortgage industry, in senior level management, he has gained experience in all areas of mortgage lending, risk management, and compliance. Mike is a past President of the MBA of Greater Philadelphia, is a charter member and was the second Chairman of the MBA of Pennsylvania, and a past board member and Legislative Chair of both associations. He is a recipient of the 1998 Mortgage Banker of the Year Award from the MBA of Greater Philadelphia, and the 2003 Chairman's Award from the MBA of PA, and currently serves on several compliance related task forces for MBA.
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