The 2018 HMDA Changes are right around the corner! While this will greatly impact your residential lending departments, have you thought about how it might affect your commercial lenders? In general, you will be required to report all home purchase, home improvement and refinancings that are secured by a dwelling. Whether they are for consumer purposes or business purpose doesn’t matter. Home equity loans secured by a dwelling, on the other hand, are only reported if they are for consumer purposes. There are also a lot of exceptions. For instance, you don’t report loans primarily for agricultural purposes or business purpose home equity loans. Business purpose loans/lines are also exempt from several of the data reporting fields. For example, origination charges, total loan costs, rate spread, etc., to name a few.
Want more information? Join us on September 14, 2017, for our 2018 HMDA Commercial Lender Essentials webinar where we will focus on the HMDA changes entirely from a commercial lender’s point of view.