If you’re a HMDA bank, you have a little over a month of the new rules under your belt. Congrats! How has it been going? Do you have it all figured out? Have you hit some snags along the way? What are your biggest headaches or concerns? Do you need additional guidance and clarification in some areas?
One of the new HMDA data requirements that is causing a lot of questions is the “Introductory Rate Period”. What is an Introductory Rate Period? What if you don’t have an “introductory” rate? Do you leave the field blank? The important thing to remember is that the Introductory Rate Period data field applies to more than a simple discounted or premium rate that’s in effect for a short period of time. For example, if you have an Adjustable Rate Mortgage (ARM) program that does not have a discounted/premium introductory rate, you still report the number of months until the first date the interest may change. In other words, for a 5/1 ARM loan, you would report “60” for the Introductory Rate Period because it will be 60 months before the rate can change.
Be sure to join us for our “HMDA One Month Checkup” Webinar on February 13, 2018. We will look at how HMDA implementation has been going so far, uncover some of the hot-button issues and more. Register for your HMDA Checkup today!