The CFPB recently updated its HMDA FAQs to emphasize that credit score(s), DTI (debt-to-income), CLTV (combined loan-to-value), income and property value MUST be reported whenever those items are relied on in making a credit decision. In other words, even if different or additional factors ultimately led to the credit decision, these fields are to be reported, when considered in your decision. Small Filers would have an exemption for these fields, except income.
HMDA continues to cause challenges! To help, we have training specific to Covered Transactions, Large Filers, Small Filers, Demographic Information, and Action Taken. Check out our Store or give us a call to see what may best fit your needs!
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!