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Beginning in 2019, lenders must report an additional 24 loan data elements under HMDA, collected for loans originated in 2018. This means lenders must be prepared by January 1, 2018, to capture these data elements. A complete list of the required data can be found at HMDA.
Lenders have expressed concerns with the additional consumer information being captured. Does this put too much of the borrower’s personal information available for public consummation? CFPB said it would address this concern; but, to date no word. We continue to wait.
Consumers should be concerned about these changes as well. Most likely, they don’t know changes are coming, nor do they know the meaning of HMDA. Unfortunately, they may find out the hard way if too much of their PII gets out to the public.
Lenders should not be waiting for any action from CFPB. Regardless of the privacy issues, the intended changes and their timing are clear. Lenders need to begin preparation to capture, and report on, the new required data NOW. Do not wait!
In addition to capturing the data, lenders should start analyzing it to determine if any potential problems exist. Check for problems with any patterns that may be viewed by the CFPB as fair lending violations. After all, why do they want all this additional information? I believe it’s not to present a gold medal to lenders who report information timely and accurately.
Let’s get ready to HMDA! Do the programming now to capture and report the new elements, along with those that are now required. Create reports that will ensure lending is being done by the rules in all areas of originations, cancellations, withdrawals, and denials. Review loans for pre and post-close defects to get ahead of the game.
Now is the time that you should be preparing for the new HMDA, not after CFPB comes knocking.
Are you ready to HMDA?
