ABA Banking Journal - September/October 2017 - 55
Submission of 2017 data The entire submission process will change for the submission of 2017 data on March 1, 2018. The new filing requirements for submission on the new CFPB HMDA platform are set forth in the filing instruction guides available on the bureau's website. Be prepared for spending time to ensure that your data edits (quality, validity, macro and/or syntactical errors) are resolved, validated and explained before you sit down to submit. Plan time for any manual work to enter this information into the portal, and have a signing officer available to submit. Any steps you can take to improve data integrity now will help you significantly in the hectic months of January and February. Expanded collection of data in 2018 By now, you likely have systems, policies, procedures and training underway to start collecting the 110 data points for loans closing in 2018. This would include data relating to applicants, borrowers and the underwriting process; the property securing the loan; features of the loan; and certain unique identifiers. You have coordinated with the business lines and the second and third lines of defense to test the data frequently throughout 2018, and you're alert for any nuances in collection, including any updates for TRID tolerance cures occurring after loan closure and loans started in 2017 that will close and be reportable in 2018. Consult the CFPB's "Summary of Reportable Data" and "Reporting 'Not Applicable'" guides for more. The most complicated area to prepare for is the collection and reporting of information for ethnicity, race and gender. Suffice it to say there is a lot evolving here. In general, report ethnicity, race and gender as provided, at the time provided. (There are nuances for 2017 applications that close in 2018.) Collect demographic data from the applicant and the listed first co-applicant only, who are individuals (e.g., not corporations). Consult the HMDA ethnicity and race collection and reporting reference tool, Appendix B, and stay alert for the April 2017 proposed amendments being finalized. By now, your cart should be overflowing with information and guidance. Look to the CFPB website for resources (many of which have been referenced here) and updates on evolving regulatory activity. And as the game begins, let us hope we will all be winners! BARBARA BOCCIA, CRCM, is senior director of U.S. advisory services and regulatory relations at Wolters Kluwer. This article is intended only to act as a quick reference and not as a substitute for the law, regulations or official commentary. SMART CREDIT STARTS WITH YOU This October, take advantage of the opportunity to join the thousands of volunteer bankers participating in the national Get Smart About Credit campaign. Raise your bank's profile in the community while bringing lessons of sound money management to young people. Get Smart About Credit Day is October 19, 2017. Register today! NEW! BANKERS AND YOU PRESENTATIONS THAT EXPLORE CAREERS IN BANKING. aba.com/GetSmart aba.com/BankingJournal | ABA BANKING JOURNAL 55
For optimal viewing of this digital publication, please enable JavaScript and then refresh the page. If you would like to try to load the digital publication without using Flash Player detection, please click here.