Regulators Designate Key HMDA Fields

Bulletin defines 37 “key fields” examiners will typically use to test and validate the accuracy and reliability of home mortgage loan data collected beginning in 2018.

11/14/17

mortgage, people, housing and real estate concept - happy family with boxes moving to new homeThe Office of the Comptroller of Currency (OCC) and other federal financial institution regulators, not including the NCUA, issued OCC Bulletin 2017-14. This bulletin designates key fields within the new HMDA data fields.

Starting on Jan. 1, 2018, the HMDA amendments will go into effect. These amendments will create additional data points that must be collected for real estate lending.

The FRB, FDIC, and OCC are issuing Designated Key HMDA Data Fields to support the efficient and effective evaluation of financial institutions’ compliance with HMDA’s new requirements. Of the 110 data fields, 37 are identified as key fields.

The bulletin lists all 110 data fields, and has highlighted the 37 key fields in bold.

Question of the Week

Under Regulation Z’s loan originator rule (for mortgage transactions), are all loan originators required to receive periodic training? Even MLOs that were registered through the NMLS prior to the new loan originator rules?

Yes. The commentary to Regulation Z states that periodic training for loan originators must be sufficient in frequency, timing, duration, and content to ensure the individual loan originator has the knowledge of state and federal legal requirements that apply to the individual loan originator’s loan origination activities.  The commentary goes on to state that the training requirements apply to individual loan originators regardless of when they were hired.

Additionally, training the NMLSR has approved to meet the licensed loan originator continuing education requirement under 1008.107(a)(2) satisfies this requirement.

Resources

Legal Briefs

National Credit Union Administration (NCUA)

The NCUA announced that its October 2017 Board Meeting Video is now available.

The NCUA announced its board meeting schedule for 2018.

Consumer Financial Protection Bureau (CFPB)

The CFPB announced that it is suing a debt relief company, Freedom Debt Relief, for misleading consumers about the debt-settlement services it could provide.

The CFPB and Federal Reserve announced the dollar threshold updates in Reg Z and Reg M that will apply for determining exempt transactions in 2018. In 2018, the protections under Reg Z and Reg M will apply to consumer credit transactions and consumer leases of $55,800 or less. However, private education loans and loans secured by real estate are covered by Reg Z regardless of the amount of the loan. .

The CFPB issued a Notice and Request for Information in the Federal Register. The CFPB is seeking information about the experience consumers are having with access to free credit scores.

Federal Reserve Board (FRB)

The FRB released the record of its Nov. 2 meeting of the Community Advisory Council and the Board of Governors. In the meeting, the group discussed mortgage access and finance reform, retail employment, labor markets, current market conditions, housing markets and additional matters, including the recent hurricanes.

The FRB released its October 2017 Senior Loan Officer Opinion Survey.

The FRB announced its approved fee schedule for Federal Reserve Bank priced services for 2018.

Financial Crimes Enforcement Network (FinCEN)

The U.S. Treasury announced that Kenneth A. Blanco will be the new FinCEN director.

Office of Foreign Assets Control (OFAC)

OFAC has updated the SDN list as of Nov. 9, 2017. The last update prior to this was Nov. 1, 2017.

 

Questions? Contact the Compliance Hotline: 1.800.546.4465, compliance@nwcua.org.