The power of conversation is an amazing thing. We get the opportunity to work with a lot of great credit unions, and when we are able to collaborate as a group it really gets the mind going. Recently we had a call with a group of credit unions to discuss the new HMDA rule. I know, I know, really exciting stuff. But at the end of the day I think the conversation paid huge dividends because there was this light bulb moment when we talked about the groups within a credit union that are going to be new to the HMDA party. I would be willing to bet the penny in my pocket that you might be in just the same boat. Lucky for you, I can help you turn on that light.
HMDA has been a “mortgage thing” for as long as I can remember. The retail and commercial staff have been able to point and laugh at the poor suckers in mortgage for the longest time now. But, they will be laughing and pointing no more. As most of you may know, HMDA now requires the mandatory reporting of HELOCs (which were optional before), as well as the reporting of business or commercial loans that are for purchasing, refinancing, or improving a residential property. Now you might be thinking, “Okay, so what is your point?
Raise your hand (even though I can’t see it), if you take and originate applications for HELOCs and residential mortgages on two different loan origination systems (LOS). Now raise your other hand if you originate investment properties on a separate LOS that is not one of the two I previously mentioned.
Is the light on yet? As you can deduct from the items mentioned above, the new HMDA rule is bringing more folks to the party, and it doesn’t matter if they wanted to come or not. If you raised one or both hands, that probably means that you have up to three different departments working on HMDA reportable loans. I will bet the other penny in my pocket that those three departments also have a different way of doing things. But when it comes to HMDA, there is only one way. One submission, and one way to report the information.
So what are you doing to get those individuals that are new to the party up to speed? Have you had conversations on how the information will flow from the different LOSs? How are you each going to capture the information? And what are some of the other things you may not have thought about when it comes to this new rule?
Interested in learning more about how these HMDA changes could affect your credit union?