The ability to import 2018 format TXT files as Private Data is now available in LendingPatterns™. The link to the file specs can be found online: https://www.consumerfinance.gov/data-research/hmda/static/for-filers/2018/2018-hmda-fig.pdf.) There is no change to available reports in LendingPatterns™. In the process of importing, LendingPatterns™ will transform your Private Data into pre-2018 format.
Our approach is to standardize the 2018 data to match 2017 analytical categories to more easily allow for comparisons across years. For lenders, this will allow you to see data from 2004-2018 on reports in LendingPatterns™. For example, the tool applies the old logic for determining high-priced loans (150 bps spread on a first lien loan; 350 bps on a second lien loan) to the 2018 Rate Spread field. Above the threshold is considered high cost. The average Rate Spread on loans that exceed the threshold is reported.
We encourage you to reach out to Support@ComplianceTech.com team for additional support on 2018 HMDA data import and/or learning how to conduct a deeper-dive fair lending analysis in Fair Lending Magic™.
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