New HMDA Rule | Builder Loan Clarification

None of These Apply at a Company (USA)
Good morning everyone! This is a follow-up to our discussion of "builder loans" at our HMDA Workshop and we wanted to make sure others also had this information. **We have confirmed with the CFPB that a construction-only loan to a builder (i.e., spec home) where the proceeds from the sale of the home are the repayment source, are HMDA reportable as purchase loans.** These loans do not meet the "temporary financing" exemption under the new rule because they are not "designed to be replaced by by permanent financing at a later time". (Section 1003.3(c)-3) They are exempt under the rule we follow today because the regulatory text specifically exempts "construction-only" loans. That language has been eliminated in the 2015 HMDA Rule text, so builder loans that are construction-only and will be repaid with proceeds from the sale of the completed home are no longer excluded from reporting requirements as temporary financing beginning January 1, 2018. As you prepare for the implementation of the new rule, you want to make sure your commercial lenders are aware of this change.

Debit Card Fraud

Employee at a credit_union ($25MUSA)
Reaching out to see how other credit unions handle this. We recently have had 2 members who have had numerous debit card transactions that they claim are unauthorized. These are not small dollar amounts either. In both cases, some of the transactions have no charge back rights as a card was present (both members have their card, so we are assuming their information was stolen and fake card created). We issue provisional credit at the time the dispute(s) are filed. Then, when the investigation results are back, if there were no chargeback rights, we write those off to our debit card losses and the member then gets to keep the provisional credit. So, we are the ones taking the hit. Just today we had our 2nd one of these situations and the total is over $1000. We are a small CU and can't continue to eat these losses on these transactions that have no chargeback rights. How do other handle this? If no chargeback rights, do you take back the provisional credit for those items or do you write it off to a g/l account for those type of losses?

Loan Payments

COO at a bank ($60MUSA)
This will be a very random processing/operations question for the community. What is your procedure for handling loan payments either from customers that mail a check or for customers that walk in a payment. Do you have tellers take and process all payments? Do you have tellers make a receipt for the payments and accept them and then have loan personnel process them? Do you your loan department handle all payments? Is there a difference for regular loans vs. participation loans? Also, has there been anyone that has expereinced trouble with one way and then decided to go another? Could you share your experience with changing it up? Was it better/more efficient?

It's Not Too Early to get your LEI!

None of These Apply at a Company (USA)
Good Evening! In the last two weeks, we wrapped up two HMDA workshops and a seminar touching on the topic as well - in those three events, we have stressed the importance of obtaining your Legal Entity Identifier sooner rather than later. The LEI is a unique, 20-digit alphanumeric identifier issue by a utility endorced by the LEI Regulatory Oversight Committee or endorsed or otherwise governed by the Global LEI Foundation (or a successor organization). We've found that the following link tends to be user friend: https:/ The process is averaging 3-5 business days from initial registration to getting your LEI and costs approximately $200 (and $20 per year). Consider this a first, easy step to check off your HMDA Implementation To-Do list!

Introducing private groups in CBANC

VP at a Company (USA)
Hi all, We've recently introduced private groups in CBANC based on requests from folks in the community. **Having a private group in CBANC provides an easy, effective way to collaborate with your peers, within your FI or within a user group that you participate in.** Here are just a few benefits of having a private group in CBANC: * Upgrade from list-serves and ditch never-ending email threads * Organize discussions around topics * Leverage a searchable, private document repository If you're interested in learning more, just reply to this discussion!

OFAC Match

Person at a bank ($88MUSA)
We have a possible OFAC match that is name only. There is nothing else to match to. What is the best way to verify a positive or a false match. This is the first time we have had this happen. Thanks.

CFPB TILA Final Rule Commentary

Employee at a bank ($548MUSA)
Good Afternoon, I've found a number of references to CFPB comments 17(c)(1)–19 "discription of general lender credits" and 19(e)(3)(i)–5 "lender credits for specific charges"; however, I have not been able to locate the document where these comments reside. The first reference is highlighted in the attached document. Which can be found on 12 CFR Parts 1024 and 1026 So far I've found that 17(c)(1)–19 was issued as a replacement for comment 18(b)2 under 1026.38(h)(3). Does anyone have any ideas as to where I might find a copy of the actual commentary referenced here? Thanks, LD