Now that you’ve had a whole two weeks to get all of the TRID changes implemented (that’s supposed to be funny), the CFPB has issued a Final Rule for HMDA. It’s a mere 796 pages. There’s also a 5 page Executive Summary, a Key Date Timeline, a Regulatory Reference Chart and an Institutional Coverage Flowchart which appear to be helpful.
Here’s some good news:
1) The new rules are not effective until January 2018. That’s right. The kind hearted CFPB gave you an extra year before you need to implement these changes.
2) Beginning in January 2017, if your institution didn’t originate at least 25 home purchased loans (or refinancings of home purchase loans) in each of the two prior years, your institution is exempt from HMDA. Refer to the Institutional Coverage Flowchart (left side, last decision point).
Rest assured, we will be reading and reading and reading the final rule and will prepare a summary soon. When it’s ready, we’ll tell you all about it in our monthly newsletter. We will also plan to have multiple training sessions on the new rules in 2016 and 2017, so you can be prepared.
Now if you’ll excuse me, I’ve got some reading to do!
David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.
He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transform the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM), and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.
David and his wife Karen have 3 adult children and 2 grandsons (none of whom live at home!) and 3 cats (of which Dave is allergic … the cats, not the children!). They live on a lake in Nebraska and when possible he can be found fishing or making sawdust in his shop. David plays the guitar & piano and enjoys singing with Karen. They occasionally lead worship at their church.