By Dennis Moore
Originators and purchasers of multifamily loans are increasingly focused on the new Home Mortgage Disclosure Act (HMDA) reporting requirements (coming in early 2018) and how they will impact their businesses.
Even though the CFPB (a non-appropriated agency responsible for HMDA) has published an official list of data points that must be submitted, some reporters are still unsure if they qualify. For example, it is unclear whether reporters must have 25 or more multifamily loans in “each” of the last two years (2016 and 2017) or “either” of the last two years (2016 or 2017) to qualify.
For several organizations, many of the required data points reside in multiple systems; the few work group attendees who currently do HMDA reporting rely on Excel and reference manual compilation and manipulation of data, which take significant time and effort. Excel lacks the proper controls, auditability, and scale that lenders need to stay on top of changing regulations.
Through the MBA, lenders can suggest changes to CFPB policies and requirements, particularly those that are not applicable to a multifamily originator’s lending operations.
So, how can you prepare for HMDA?
- Attend the MBA’s monthly HMDA meetings to hear new announcements
- Analyze the number of multifamily loans you originated and purchased in 2016 and 2017
- Document your HMDA processes and procedures
- Evaluate how HMDA will be supported in your software
SS&C has extensive accounting policy, regulatory reporting, and software development expertise. We also have a strong track record of delivering new functionality to support emerging regulatory requirements based on client needs and industry mandates.
Our Precision LM software helps you maintain regulatory reporting compliance. We are committed to staying engaged with the MBA and our clients to roll out new HMDA functionality before the changes go into effect. Our goal is to create a consistent, efficient, and scalable way for our clients to report the requisite HMDA data to CFPB.