Month: July 2018

fair with wooden blocks

The Expectation of Exceptions in the World of Fair Lending

Exception reporting is not new; all banks are required to report loan policy and loan documentation exceptions for Safety and Soundness. However, a new unwritten rule is fair lending exception tracking covering pricing and underwriting exceptions on consumer loan products. Whether it’s HMDA for banks with less than or more than 500 entries, regulators want …

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HMDA Reporting Requirements: Business Purpose Loans

The passing of Senate Bill 2155 adds another level of complexity to an already complex Regulation. The Bill exempts institutions that originate fewer than 500 closed‐end loans or open-end lines of credit in each of the two preceding calendar years from reporting certain HMDA data points. This “relief” spurred the question, “What and how do …

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HMDA Reporting Requirements: Business Purpose Loans

The passing of Senate Bill 2155 adds another level of complexity to an already complex Regulation. The Bill exempts institutions that originate fewer than 500 closed‐end loans or open‐end lines of credit in each of the two preceding calendar years from reporting certain HMDA data points. This “relief” spurred the question, “What and how do …

HMDA Reporting Requirements: Business Purpose Loans Read More »

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