HMDA: Why Its Important to Get It Right

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Understanding HMDA

## Episode Summary
In this episode of With Flying Colors, host Mark Treichel interviews Joe Goldberg, a retired NCUA consumer compliance expert, about the Home Mortgage Disclosure Act (HMDA). Joe provides an in-depth overview of HMDA, its purpose, requirements, and importance for credit unions.

## Key Points
1. HMDA Background and Purpose
- Enacted in 1975 to address housing issues and prevent discrimination
- Provides over 45 years of good mortgage data

2. HMDA Requirements
- Applies to credit unions meeting specific criteria (asset size, location, loan activity, and volume)
- Requires collection and reporting of 48 data points on mortgage applications and loans

3. Data Collection and Reporting
- Data must be recorded in a Loan Application Register (LAR)
- LARs must be updated quarterly
- Annual submission deadline: March 1st of the following year

4. Partial Exemptions
- Available for institutions originating fewer than 500 covered closed-end mortgages or open-end lines of credit
- Reduces reporting requirements from 48 to 22 data points

5. Use of HMDA Data
- Regulators use it for fair lending programs and compliance checks
- Credit unions can use it to assess their performance and improve fair lending programs

6. Compliance Tips
- File data even if late to avoid more serious violations
- Utilize resources like FFIEC's "Getting It Right Guide" and CFPB's website

## Notable Quotes
"HMDA goes back to 1975, which is when it was enacted. And so, as a result of that, we actually have mortgage data, good mortgage data, going back for over 45 years."

"Even if you're late, file the data."

"I just think it's important for credit unions to understand, though, that even though complying with HMDA can be a chore, that there is a valid reason for collecting the HMDA data, and that is to try and ensure that mortgage credit is offered and extended to everybody based on mortgage related criteria."

## Resources Mentioned
- NCUA Regulatory Alerts
- FFIEC Website (www.ffiec.gov)
- FFIEC's "Getting It Right Guide"
- Consumer Financial Protection Bureau Website (consumerfinance.gov)
- Lending Patterns software by Compliance Tech (used by NCUA)

## About the Guest
Joe Goldberg is a retired NCUA consumer compliance expert with over 40 years of experience as a lawyer. He has taught consumer law and worked in various aspects of financial regulation.

## Sponsor
This episode is sponsored by Credit Union Exam Solutions by Mark Treichel. Visit marktreichel.com for more information on optimizing your results with NCUA.