Sheila Latiff and Meaghan James in Housing Wire about Impact of HMDA changes on LenderDecember 15, 2017
Sheila Latiff, Senior Director and Meaghan James, Staff Attorney at Digital Risk were quoted in Housing Wire in the article titled "Your top 10 HMDA questions answered: Part 3" talking about implications of the recent amendments and publications to HMDA on a lender.
Speaking about the hidden traps that can entangle not only lenders but borrowers as well, Digital Risk Senior Director Sheila Latiff agreed it will present a challenge on the technology side.
"Systems must be updated and edits included to ensure as much accuracy as possible," Latiff said. "Additionally, even if an application was taken in late 2017 – unless there was 'Action Taken' as defined by the regulation that application is subject to 2018 requirements. This means that lenders must have proactively incorporated the additional data elements into their LOS prior to effective date in 2018." She explained that originators aren’t the only ones who will need to be careful of the new changes, but also those who buy loans.
"For lenders that buy loans, data integrity issues are sure to crop up – particularly if either loans being purchased weren’t carefully monitored as described above, or if loans being purchased have incorrect data," Latiff told HousingWire. "Scrubs of data by the purchasers will need to occur to ensure adherence to the new HMDA requirements."
Another expert from Digital Risk, Staff Attorney Meaghan James explained that while the changes can be overwhelming, it doesn't need to feel like TRID all over again.
"Most importantly, the HMDA amendments mean that lenders have had to make serious changes to their software and infrastructure, as well as policies and procedures, to ensure that the new and revised data points are properly captured and reported," James said. "Furthermore, lenders need to implement training across all departments to ensure that all appropriate staff understand the changes and are prepared to identify what data needs to be captured and when."
"In conjunction with this training, lenders should be, if they haven’t already, communicating these changes to executive leadership and the board; compliance is an all-inclusive function and it is important to have all levels of staff involved and aware, especially when there are changes as widespread and important as this," James said.