When it comes to advertising, some regulations like the Truth in Savings Act (Regulation DD), provide exemptions (as far as certain disclosure requirements) when using electronic media. But, not all do.
Listen to the video as Dave explains.
This is the kind of thing we are going to address during our Advertising Webinar on April 16th. We will look at the advertising requirements for deposit products, as well as loans, and even get into UDAAP, bonuses, and more. We’ll even discuss how to get your marketing people and compliance people on the same page. We hope you’ll join us!
You would think reporting the loan term (field #82) for HMDA would be fairly straightforward but it can actually be quite complicated!
If you have a closed-end loan, you can forget the odd days and just report the number of whole months between the first payment and loan maturity. Imagine you make a loan today and the first payment isn’t due for about 50 or 60 days. You start counting with that first payment. So, if you’re making a 30-year loan, you’d have 360 months.
If you have an open-end line of credit, you also forget the odd days and report whole months, but you start counting from line origination to the maturity date. So, your loan term may differ depending on whether you have a loan or a line.
If we look at the next data field, the introductory rate period (#83), it doesn’t matter if it’s closed-end or open-end, you count from loan/line origination until the first rate change. So, again, you could likely have different answers for the introductory rate period than you do for the loan term.
These are the kind of things we will talk about in our upcoming webinar, HMDA: Advanced Lessons. On April 11th, we will spend two hours talking about the things that are causing the most headaches. We are going to assume that you understand HMDA and dig a little deeper at a higher level. So, we’ll get into mixed-use properties, demographic information and Reg B vs. Reg C vs. TRID when it comes to applications. We’ll also look at Reg B vs. Reg C when it comes to action taken codes and more.
If you are a Small Filer for HMDA, there is a laundry list of data fields you are not required to report.
There are seven fields; however, that if you voluntarily report some of the information in that field, you must report all the information relative to that field. For example, if you are going to report the credit score, then you have to also report the scoring model that it came from. Just because you report the credit score, though, doesn’t mean you have to report the reasons for denial. It’s not like you’re required to go all-in on all the data. It’s just if you go in on any of those seven, then you have to give all the corresponding data for that specific field.
Check out the video as Dave gives more information on other Small Filer reporting issues. Specifically, reporting NA, reasons for denial, property address, collecting but not reporting certain fields, etc.
These are the kinds of things we will cover at our “HMDA Data for Small Filers” webinar on March 28, 2019. We’re going to spend one hour going line by line and getting into the weeds about the data you are exempt from as well as the data you’re still required to report. See you then!
When it comes to flood insurance coverage, you have to look at the “lesser” of three things…the loan balance, the insurable value, and the maximum available through the National Flood Insurance Program. While the loan amount and the NFIP limits are pretty easy to come up with, determining the insurable value can be troublesome. This is because there isn’t just one way to determine insurable value.
Listen to the video as Dave walks
you through some of the confusion.
This is just one of many flood insurance topics that we will cover in our two-part Flood Insurance webinar series on March 19th & March 26th. We will walk you through flood insurance from A to Z in plain English and help demystify these complicated requirements. See you then!
When it comes to HMDA banks that are not eligible for the partial exemption (aka large filers), there are a couple of things to keep in mind.
The first is the combined loan to value ratio (CLTV). This ratio includes all debts and all collateral. Imagine that you’re doing an 80/10/10 loan so the borrower can avoid PMI. Let’s say the house is worth $100,000 and you make a first lien loan for $80,000 that will be sold on the secondary market. You also make a $10,000 subordinate lien loan that you will keep in house. The collateral value is $100,000 and “all debts” securing the property is $90,000. Thus, the CLTV would be reported as .9 (90,000/100,000 = .9) for both of them.
Let’s add another twist. Say your loan is secured by the dwelling and some other type of collateral, like a car. Remember, the CLTV looks at all debts and all collateral, not just the dwelling. So, you would have to factor the value of the car into your CLTV calculation.
What gets even trickier is when you report the “Property Value” data field. Is that based on just the value of the dwelling or is it all collateral similar to the CLTV field? Join us on March 14, 2019, to find out the answer. During our “HMDA Data for Large Filers” webinar, we will be walking through all the HMDA data requirements for large filers, line by line. Find out some of the common errors and get your questions answered. We hope to see you then!