RATA
CFPB Not Accepting Leading Zeros or Hyphens in HMDA Respondent ID
It has come to our attention that the CFPB is still making changes to the 2017 HMDA submission portal. We have just heard (1/9/18) that they changed the formatting of the Respondent ID field. It is now required that all institutions remove leading zeros and the hyphen for those reporters that use their Tax ID as Respondent ID. The hyphen is still required for the Tax ID field. This represents a huge hurdle for the industry because all HMDA submission tools are designed to make that field 10 digits. This was not mentioned in the 2017 FIG and did not flag as an issue when institutions uploaded test files to the HMDA Platform. Now a recent change causes a syntactical edit, S025, when leading zeros or hyphens are present in the Respondent ID field. Your submission file will not be accepted if…
HMDA enforcement defanged by Trump-led regulators
December 22, 2018 It's been a major issue for our industry. In fact, one of our feature stories for the December magazine, written by our Managing Editor Sarah Wheeler, details the new risks HMDA reporting represents for lenders. And earlier this year HousingWire warned lenders that if they think compliance is hard now, just wait until the new HMDA regulations kick in. Most of the 2015 updates to HMDA take effect in January 2018. However, now, both the Office of the Comptroller of the Currency and the Consumer Financial Protection Bureau — both now led by Trump-administration leaders (more, below) — announced they will not be assessing penalties on HMDA data collected in 2018 and reported in 2019. What's more, the CFPB also intends to open a rulemaking to reconsider…
CFPB Issues Public Statement on HMDA Compliance
December 21, 2018 HMDA, which was originally enacted in 1975, requires many lenders to report information with respect to applications they receive for certain types of mortgage loans and certain loans that they purchase. The Dodd-Frank Wall Street Reform and Consumer Protection Act directed the Bureau to expand the data collected and reported under HMDA to include additional information regarding, for example, mortgage loan underwriting and pricing, and authorized the Bureau to require other data. To that end, the Bureau issued a rule in 2015 that requires financial institutions to collect and report additional mortgage information beginning on January 1, 2018. In August 2017, the Bureau issued a final rule making technical corrections, clarifying certain reporting…
Annual Geography Changes for 2018
The FFIEC released the geography changes for 2018 reporting on December 21st which incorporates changes made by the Office of Management and Budget as published on August 15, 2017. The change involves the creation of a new Metropolitan Statistical Area, 46300 - Twin Falls, ID which consists of 5 census tracts in Jerome County and 16 census tracts in Twin Falls County. This is the only geographical change for 2018 as part of the annual geography updates. This update is being released as a Demographic Data update to Comply for the 2018 reporting year and should be applied to your system before 2018 data collection begins. If you have any questions please feel free to contact us.
RATA Incorporating the New CFPB Geocoder
The CFPB has announced in various documents that it will be developing and making available a new geocoder to help reduce the geocoding burden and theoretically standardize geocoding results. They already had the FFIEC geocoder that could have been used for this, but apparently they believe they can do better than that. They have even said that institutions who use this geocoder will receive safe harbor if their product gives the wrong result. If that is the case, institutions will definitely want to use that geocoder whenever possible. To make sure that institutions can take advantage of this safe harbor and also get the best geocoding results possible for addresses the CFPB can't hit, RATA will be incorporating the CFPB geocoder into our processes. With RATA's cloud-based geocoding…
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