Angela Rankin

The passing into law of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) provided institutions with a partial exemption of some data fields under HMDA. One of the fields in the exemption is the Universal Loan Identifier (ULI) and allows institutions to report a Non-Universal Loan Identifier (NULI). The difference between the two […]

You must admit, defining what is a business day when it comes to lending regulations can be very confusing. Based on the questions we get from clients during our compliance reviews and through our compliance hotline, we find that lending staff is inconsistent and uncertain on how to count business days versus calendar days when

We have received numerous questions about how to report multiple properties on the HMDA LAR for 2018. Quite frankly, it can be very confusing because some fields are reported on the property securing the loan and other fields are reported on the transaction. The commentary for §1003.4(a)(9) – 2 states the following: MULTIPLE PROPERTIES WITH

On August 30, 2017, FinCEN issued a memorandum titled “Memorandum on Financial Institution and Law Enforcement Efforts to Combat Elder Financial Exploitation.” Elder Financial Exploitation is the improper use of an older person’s funds or assets. Assets can also include the older person’s property or belongings. When an older person is being exploited, it often

The long-awaited deadline to begin collecting 2018 HMDA data is here! Banking agencies have issued HMDA guidelines on data testing and additional information on HMDA data collection. Also, the Consumer Financial Protection Bureau (CFPB) has clarified some interpretations as it has worked through numerous questions via phone calls and emails from filers. One of the