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On April 16, 2020, the CFPB published a final rule that will exempt approximately 1,640 financial institutions from HMDA reporting in the future. In short, these new changes to HMDA rules are adjusting the qualification requirements to determine which financial institutions must report HMDA going forward, and many small reporters will now be exempt.
Specifically, the CFPB’s final rule made two new changes:
Effective July 1, 2020, the final rule permanently raises the closed-end coverage threshold from 25 to 100 closed-end mortgage loans in each of the two preceding calendar years.
Effective January 1, 2022, when the temporary threshold of 500 open-end lines of credit expires, the final rule sets the permanent open-end threshold at 200 open-end lines of credit in each of the two preceding calendar years.
If you are one of the 1,640 institutions who will now be exempt due to the change in the closed-end mortgage loan coverage threshold, this is something to celebrate as HMDA burdens are significant for any HMDA filer! However, it is important to understand that there are a few things you need to know about the rules. Specifically (and unfortunately), you can’t simply just walk away from HMDA immediately as there are two things that must happen.
That is right - there are a number of things you need to do, unfortunately, before you can be done with HMDA rules.
First, the final rule doesn’t permit you to cease HMDA collection prior to July 1, 2020 and requires a few things from current reporters before they become exempt. Secondly, newly exempted reporters will need to transition to government monitoring information (GMI) collection under Regulation B, which has a number of challenges of its own. Similar to HMDA demographic information collection, GMI collection under Regulation B has a number of complexities that will require appropriate training of your team. In fact, Reg B data collection errors are a very common finding during audits and exams, so it will be important that your lending team is able to sufficiently transition from HMDA data collect to GMI collection under Regulation B.
This program (which you can view today) will cover everything you need to know about the brand new changes to Regulation C and HMDA reporting that become effective on July 1, 2020. For example, this program will answer the following questions:
Who will be exempt from reporting closed-end loans?
Who will be exempt from reporting open-end loans?
What loans are counted for institution eligibility? [Note, this number isn’t your LAR total, so a bank that had 120 or 140 entries on their LAR could possibly qualify for the exemption.]
When can newly exempt institutions stop collecting HMDA data? [Note: You can’t stop collecting just yet!]
What information will need to be collected starting on July 1, 2020? [Note: Regulation B collection requirements will still apply.]
Can newly exempt HMDA reporters still collect Demographic Information under HMDA or do they now have to follow the Regulation B Government Monitoring Information rules?
What should a financial institution do who is now exempt, but believes it will no longer be exempt within the next few years due to loan origination growth?
Can financial institutions voluntarily report HMDA data?
Why would a financial institution want to voluntarily report HMDA data?
As newly exempt HMDA reporters will need to (eventually) transition to following the Regulation B rules, this program also provides a downloadable video that can be used to walk your lending team through the government monitoring information collection requirements in Regulation B. [Note, the Reg B collection requirements are substantially different than HMDA requirements, so financial institutions should ensure their team members understand the difference in the rules and what will be expected of them after they no longer collect Demographic Information under Regulation C.]
Our goal in creating this program was to provide a quick and easy-to-understand solution that walks newly exempt HMDA reports through everything they need to do when transitioning out of being a HMDA reporter. If you want a quick explanation of the nuts and bolts of what you need to do, this might be a great solution for you.
BONUS! Plus, we’ve added a bonus 10-Step Implementation Plan to assist newly exempt institutions in understanding everything they need to do in order to transition away from being a HMDA reporter.
$249 - Special Discount (Limited Time Offer - Regular Price: $329)
Watch this video for an overview of what will be covered in this class and some things to watch out for with the July 2020 HMDA changes:
The class is presented in a single video and provides an overview of the requirements for financial institutions:
Overview of the changes to Regulation C
Determining institution coverage for closed-end loans
Determining institution coverage for open-end loans
Requirements for exempted institutions
Collection & reporting requirements until July 1, 2020
Transitioning to Regulation B
Three ways to transition to Reg B
GMI collection requirements under Reg B (provided as a separate downloadable video that can be used to train your lending team)
[NOTE: As a bonus, we are providing the slides used in this training as a PowerPoint download so that bankers who want to conduct their own training can use our slides as a starting place.]
This Compliance Class provides you with a comprehensive look at the July 1, 2020 changes to Regulation C and what that means for those financial institutions who will be exempt going forward.
The class includes the following:
A comprehensive manual
A “virtual classroom” instructional video
60-day access to the class
Certificate of completion (1 per registration - available upon request)
BONUS - 10-Step Implementation Plan
BONUS - PowerPoint Slides for GMI Collection Under Reg B (from Video 2)
All of our Compliance Classes are presented in our virtual classroom approach. This approach is designed to bring the presenter to you (at a fraction of the cost of having a live person) and includes a video of the presenter in front of a slide presentation that replicates a typical seminar environment. In addition, our presenters take a three-part approach to compliance instruction: to educate, to empower, and to entertain. This is achieved by focusing on relevant topics, speaking in simple to understand, layman's terms, and by keeping it light and humorous whenever possible. We have found that this "3-E" approach allow students to learn as quickly and effectively as possible. And, it adds a little bit of fun to an otherwise dreadful topic.
Certificates of completion are now available upon request. One certificate is available per registration.
When you purchase this compliance class, you get instant access to the online version of this class for 60 days. You will also receive an electronic version of the accompanying manual to keep.
We believe in our training products so much that we are offering a 100% money back guarantee. If you do not feel that you received the value promised for this training session, contact us within the first 10 business days after purchase and we will either make things right or provide 100% of the purchase price back to you.
