The CFPB has released an updated version of the HMDA Small Entity Compliance Guide. We’re not certain why it’s called a “small entity” guide, as any institution subject to HMDA would benefit from reviewing it. It also has nothing to do with small entities and is certainly not small being it’s 138 pages long!
The guide was updated to reflect the “small filer” exemptions granted earlier this year (loans between 25-499 in each of the last 2 years). There are also some clarifications to other parts of the regulation. For example, Section 4.1.2 clarifies which transactions count when determining if a loan-volume threshold has been met. Section 5.8. clarifies the loan amount to report when a counteroffer is made. There are other numerous technical corrections throughout the Guide, as well.
We encourage you to review the Guide to ensure you are on the right track! If you need more HMDA training, we’ve got the solutions! We’ve conducted several webinars in 2018 and have more planned for 2019 that can provide with you an in-depth training on the requirements of this complicated regulation. Check out our store for these great training opportunities!
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 transforms 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 three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.