HMDA 2018 Changes: Business purpose loans now covered. Do these changes affect you and your lending business?

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The Home Mortgage Disclosure Act (HMDA), which Congress enacted in 1975, requires certain financial institutions to collect, record, report, and disclose information about their mortgage lending activity. Regulation C implements HMDA and sets out specific requirements for the collection, recording, reporting, and disclosure of mortgage lending information.

Effective January 1, 2018, sweeping changes occurred regarding the data that must be collected and who must collect the data. Under 2018 HMDA rules, Business Purpose loans are now included as loans that need to report data. This is a major change as previous business purpose loans were excluded from the HMDA reporting thresholds. Many lenders and brokers who have not needed to report before, will need to gather and report HMDA data for the 2018 calendar year.

Geraci LLP’s attorneys are experts in HMDA compliance and have prepared a guide that will answer the following questions:

  • Do I need to report?
  • What data points must I collect?
  • How do I report the collected data to the CFPB?

The 2018 Compliance Guide is available to Geraci LLP clients for $495 and $1,295 for all others. Please contact Bryan Redington at B.Redington@geracillp.com or call (949) 236-6093 to purchase your guide.

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