Hope this is helpful. It took us a while to get this document fillable. This document comes with a disclaimer. It has not been approved by examiners or an attorney. Use at your own risk.
Can someone point me to a section of any regulation that states that a Heloc loan documentation needs to state that the lien being placed on the property is in first or 2nd lien position? We capture the information for HMDA related purposes in our LOS 1003, but we do not document lien status on any documents that are sent to the borrower.
It's that time of year again - your HMDA data has been filed with the federal government. The regulators have your HMDA (and CRA) LAR now, so the time is ripe for you to take a deep breath and think about your goals for the rest of the year.
Now that you've filed your HMDA data, here are the 10 things you need to do: https://www.trupointpartners.com/blog/10-things-to-do-after-submitting-your-hmda-data
If the loan is in the name of a trust and the primary residence is the collateral, for the HOEPA status should we report a 1 or 2 in the field? It states that if consumer purpose report a 1 or 2. However, since a Trust is not a person do you state a status or is it not applicable, like a loan to a business?
We use LOS where the data is inputted for collection purpose from the 1003 then exported to QuestSoft. any information would be helpful. Thank you
Needing guidance on how to report a loan which received an AUS approve eligible but was subsequently denied due to collateral (something AUS can't read such as mold, etc)? Do you list the AUS approve eligible then list a 2nd risk assessment such as "Other" or show "Not Applicable" as the only AUS finding? Thanks
We are a first time HMDA reporter and will be filing with the small filer exemptions. We have purchased a pool of loans located in Puerto Rico. We cannot pull our usual census tract information but will need to gather the longitude/latitude and use a special site to obtain this information. Is anyone aware of any exemption for census information for purchased loans located in Puerto Rico? Appreciate any advice on this.
Would anyone please share their HMDA policy if you're a bank that is able to take advantage of the partial exemptions? Thank you!
Learn the four phases that all HMDA data goes through in its yearly lifecycle, plus best practice strategies to make each stage a success. You'll also get a free infographic illustrating the HMDA data timeline that you can print and share with your team: https://www.trupointpartners.com/blog/hmda-data-lifecycle-timeline
It seems like there is a regulatory update to the Home Mortgage Disclosure Act every minute! Just last month, the CFPB released updated information about the HMDA data that will be disclosed in 2019. If you're a HMDA reporter, this post is for you. Plus, you'll also get access to a new-and-improved version of our insanely popular Guide to the HMDA Changes! Don't miss it.
Good morning everyone,
Looking for guidance from other HMDA reporters that use Encompass.
Currently, in Encompass, we are using the Mavent auto-populating setting to populate our Rate Spread Calculations for HMDA reporting. Every time we run Mavent, it calculates the Rate Spread and populates it to the HMDA info screen, which populates to our LAR. The problem we are encountering is that the APR that Mavent is using to calculate the Rate Spread is the one it calculates (based on fee mapping), and this value is not always the same as the value that we are disclosing on our CD, which is where the Reg tells us to get the APR. This can happen for a number of reasons, most of which deal with known limitations of Mavent. Our disclosed APR is correct, but the calculated rate is not. Most often it is with Construction-Perm loans. There are also issues with fees being mapped differently in Mavent, than how the fee is being paid or used in the loan. Finally, there appear to be some rounding issues.
All of these issues would not cause problems with Rate Spread if Encompass calculated it based off the Disclosed APR instead of the APR it is calculating.
What we want to know is:
• Can we change this setting on the user end to use the disclosed instead of calculated value?
• If not, what is the Ellie Mae logic in using the calculated value when the Reg seems to be clear that the disclosed value should be used?
Have any of you worked through this? All input appreciated!
Do you have to meet all of the institutional exemptions (asset size, location and transaction) critiera for reporting HMDA or if you meet one of these critiera are you considered to be exempt from HMDA reporting?
We have a property with a primary residence and also a guest cottage. The guest cottage is currently not habitable without repairs being made but there is no plans to repair. Do we report 1 unit or 2 units for total units?
We have a property with multiple dwellings (rentals). One of the dwellings on the property is currently being built but the loan is not a construction loan. The roof and outside walls are in place but the dwelling isn't finished on the inside yet. Do we include this dwelling in our count for number of units?