When reporting Loan Costs, Points, Fees, Origination Charges and Lender Credits on your HMDA-LAR, there are many inconsistencies that just don’t make common sense. For instance:
1) Just because you provide a Closing Disclosure, doesn’t mean you will report these five items. If the loan were to not close for whatever reason, you would report all of these as “NA”.
2) If you are required to report these five items, and the answer is none, there are inconsistencies between these five. For Total Loan Costs, Total Points and Fees, and Origination Charges, you enter a “0”. But for Discount Points and Lender Credits, you leave the field blank.
3) If a corrected Closing Disclosure is provided to the borrower “… the financial institution reports the corrected amount…” BUT that’s only true if the corrected Closing Disclosure is provided in the same calendar year. Assume you closed a loan on December 29th and provided a corrected Closing Disclosure on January 2nd. In that case, you do not report the corrected amounts. [Commentary to §1003.4(a)(17)(i) #3, Commentary to §1003.4(a)(18) #3, Commentary to §1003.4(a)(19) #3 and Commentary to §1003.4(a)(20) #3]
We’ll be clarifying these issues and more in our HMDA Advanced Lessons webinar on May 3, 2018. Join us to get greater clarity on the many confusing HMDA issues!
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.