The September release of the 2014 data submitted under the Home Mortgage Disclosure Act (HMDA) has several uses. In this article, we discuss the utility of these data in evaluating your institution’s exposure to HMDA compliance risk related to two data categories: government monitoring information and action type coding. By benchmarking your organization’s performance against [...]
In a recent Knowledge Center post, we discussed four common errors that lenders encounter when satisfying reporting requirements under the Home Mortgage Disclosure Act (HMDA). The four errors that we reviewed – failing to capture all HMDA-reportable transactions, documenting an incorrect loan amount, assigning the wrong geographies via geocoding, and making errors in calculating the [...]
The Home Mortgage Disclosure Act (HMDA) requires covered institutions to make loan information available to the public. Regulators, examiners, academics, industry leaders, and members of the general public rely on these data to analyze the performance of mortgage lenders in achieving the goals established under the Equal Credit Opportunity Act (ECOA), the Fair Housing Act [...]
In this contribution to ADI Adviser, ADI Senior Economist Paul J. Strasberg discusses the need for a dynamic analysis plan in modeling underwriting processes. Paul demonstrates how the dynamic approach is "better aligned with the process used by lenders, results in lower and well-identified high risk cases, and should be well received by regulatory authorities." In addition, [...]
New HMDA data collection requirements will most likely be issued this year, although the final scope and details, along with a date for when the regulations will go into effect, are still unknown. The extent of additional data collection fields required, and the changes in types of loans that will need to be reported, will be significant. Meeting these new requirements [...]
About the Author: Jonathon Neil Jonathon is a Senior Consultant for ADI with expertise in Fair Lending compliance, CRA compliance, data mining, and geographic information systems. You can contact Jonathon at jneil@adiconsulting.com or 703.665.3707.
On October 21, 2014, the Federal Reserve Board hosted its periodic Outlook Live series webinar, which focused on hot topics in Fair Lending. Presenters from several agencies summarized and shared insights on various areas of focus regarding Fair Lending compliance. Here are some of the main takeaways from the presentation. Fair Lending risk from target [...]
On September 22, 2014, in accordance with the Home Mortgage Disclosure Act (HMDA), the FFIEC released to the public the HMDA database for the 2013 reporting year. The public data can be leveraged as an asset that can support Fair Lending and CRA compliance as well as marketing efforts. The following are five ways lenders [...]
Recently, the Financial Crimes Enforcement Network (FinCen) imposed a $75,000 penalty on Colorado money services business, Aurora Sunmart Inc., and its owner and General Manager, Jamal Awad, for violating Bank Secrecy Act (BSA) requirements. FinCen asserted that Aurora and Awad “willfully violated” the BSA’s registration, program and reporting requirements and also did not have an [...]
BSA oversight and regulation has increased sharply over the past couple of years. BSA and compliance officers share stories of the aggressiveness of regulators and granular scrutiny that examiners are putting both large and small institutions through. The good news from this increased oversight is the number of formal regulatory actions (written agreements and Cease [...]
