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!
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager.
Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelor’s Degree in Business Administration, and is a graduate of the ABA Compliance School.
Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!