You would think reporting the loan term (field #82) for HMDA would be fairly straightforward but it can actually be quite complicated!
If you have a closed-end loan, you can forget the odd days and just report the number of whole months between the first payment and loan maturity. Imagine you make a loan today and the first payment isn’t due for about 50 or 60 days. You start counting with that first payment. So, if you’re making a 30-year loan, you’d have 360 months.
If you have an open-end line of credit, you also forget the odd days and report whole months, but you start counting from line origination to the maturity date. So, your loan term may differ depending on whether you have a loan or a line.
If we look at the next data field, the introductory rate period (#83), it doesn’t matter if it’s closed-end or open-end, you count from loan/line origination until the first rate change. So, again, you could likely have different answers for the introductory rate period than you do for the loan term.
These are the kind of things we will talk about in our upcoming webinar, HMDA: Advanced Lessons. On April 11th, we will spend two hours talking about the things that are causing the most headaches. We are going to assume that you understand HMDA and dig a little deeper at a higher level. So, we’ll get into mixed-use properties, demographic information and Reg B vs. Reg C vs. TRID when it comes to applications. We’ll also look at Reg B vs. Reg C when it comes to action taken codes and more.
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.