What this Means
While this is obviously good news for some of you, it doesn’t come without additional compliance implications. If you’re affected by either of these changes, you are going to need to retrain your lenders.
Even if you are no longer subject to HMDA data collection/reporting, you ARE still subject to Regulation B.
While these changes may result in you no longer collecting race, sex and ethnicity information for HMDA (dwelling-secured applications for loans (and/or lines) for home purchase, home improvement, refinance or consumer home equity), you will still need to collect Government Monitoring Information (GMI) under Regulation B.
Regulation B’s collection requirement only applies to applications primarily for the purchase or refinancing of an applicant’s primary residence (1-4 family dwelling) that will be secured by that same dwelling.
It’s pretty easy to see that your lenders are going to need to be retrained if these changes affect your institution. We can help! First, if you need more information on these HMDA Changes, we have a webinar, “NEW! 2020 HMDA Final Rule”, which is available NOW On-Demand. Second, we will be hosting a webinar, “Collecting GMI Under Regulation B”, on June 3, 2020. This webinar will walk you through the ins and outs of transitioning from HMDA to Regulation B, collection forms, Fair Housing logs (for OCC Banks) and more!
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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.