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
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!
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.