When it comes to your client’s data, your main priority should rightly be keeping it secure from any third parties. However, when the time comes to deliver the data and you have accidentally omitted a piece of information, it can have serious consequences for you and your business.
Here is a brief update about HMDA data requirements and penalties incurred if conditions aren’t met.
With only a few months left before your March 1 filing, now is a good time to plan the year-end HMDA scrub. The point of a HMDA Scrub is to compare specific data in the loan application register (LAR) to loan origination source systems (LOS) or physical loan documents. There are several reasons why you should always do a HMDA scrub. Read Here
Fair lending analysis attempts to use lending transaction data to tell the story of the evenhandedness of underwriting, pricing, and marketing decisions in terms of what happened when, where, why, how, and to whom. Fair lending compliance managers may use HMDA data to quantify fair lending risk in several ways – Read Here
Too often the mention of the four letters, H M D A, causes heartburn among lenders. I suppose this is understandable because HMDA is associated with compliance, regulation, race, and lawsuits. HMDA data are really a blessing to the mortgage lending industry by providing a national digital trail of every mortgage application and its underwriting outcome. Can you think of another private industry that makes public the who, what, and where of every transaction with consumers? I can’t think of any. Read Here
So, I thought it might be helpful to tick off a few of the ways HMDA data analysis could be used, operationally, to help lenders strategize, plan, compete and make managerial decisions.
As the year 2021 winds down, it is time to start thinking about ensuring that your HMDA submission is ready to be filed by March 1, 2022. Before the end of this year Compliance Officers, and those ultimately responsible for the HMDA submission signoff, should use this time to make sure that the HMDA data not only pass the CFPB’s edits checks but also pass lending industry-based sanity checks.
Here are three reasons why it is important to go beyond the HMDA Edit Checks before submitting your data to CFPB. Read Here