One question we get frequently about the 2018 HMDA rules is how to transition from 2017 requirements to the 2018 requirements. For example, what do you do with a HMDA application that’s received in 2017 but the loan won’t be closed until 2018? There’s actually a couple of different things to consider:
- When it comes to collecting Government Monitoring Information (GMI)/Demographic Information (DI), you can follow the 2017 GMI collection rules, for an application received in 2017. If you collect GMI in 2017, you will report it that way (without subcategories) on your 2018 HMDA-LAR. You also have the option to follow the 2018 DI collection rules for applications received in 2017. If you collect DI in 2017, you may report GMI (without subcategories) or DI (with subcategories) on your 2018 HMDA-LAR. The CFPB created a helpful chart as a guide.
- Outside the GMI/DI rule stated above, there are no other transition rules. Any application with a 2018 action taken date will need to have all of the new data required by the 2018 rule collected and reported on your 2018 HMDA-LAR.
Want a last-minute refresher on collecting Demographic Information? It’s more difficult than you may think. Be sure to join us for our HMDA Demographic Information Collection webinar on December 7, 2017.