Be sure to JOIN US on April 16, 2020, for our webinar, “HMDA Data for Large Filers”.
HMDA compliance is tough! With all the data large filers are required to collect and report, there are bound to be mistakes. You can’t rest easy though because too many errors can lead to civil money penalties. This webinar will look at the data requirements for large filers and highlight some of the data fields that cause the most confusion. A couple of those confusing data fields include the “loan term” and the “introductory rate period”.
Click on the video to listen to Dave explain more.
HMDA Data Terms
Hi Dave Dickinson with Bankers Compliance Consulting. I want to talk HMDA and some of the quirky data fields that you have to deal with. Specifically, let’s talk about loan term, that’s data field number 82, and introductory rate period, data field number 83. Now small filers, you’re exempt. You don’t have to worry about this. But large filers, let’s get into the weeds. All right.
If it’s a loan, non-revolving credit, then you count loan term, not from origination to maturity but from first payment until maturity. So we close a loan today. You might have some odd days and then a full month. That first payment, from there until loan maturity, that is the loan term.
But wait, when it comes to revolving credit lines, you count from origination until maturity, not from the first payment. So origination and maturity for revolving credit. From first payment to maturity for non-revolving credit.
Easy enough, you say. Introductory rate, that’s field number 83. I don’t care if it’s a loan or a line, it’s from origination until the first change that can occur. Not from first payment but from origination until that first change can occur. That’s the kind of stuff you’ve got to get into the weeds if you’re a HMDA filer.
I hope this helps. Let us know if you have any questions when it comes to HMDA or any other regulatory compliance questions that we can help you with. Thanks for listening.
Other Upcoming Lending Webinars:
April 14th – Refinance, Modifications & Renewals
April 15th – COVID-19 Regulatory Update
April 16th – HMDA Data for Large Filers
April 23rd – HMDA Data for Small Filers
May 5 – Regulation B Joint Intent
Want more Free Lending tools? See here – https://store.bankerscompliance.com/link/LendingFD
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.