Course Description

Before your institution ever reports a single field to the CFPB, you need to define your internal HMDA rules clearly and consistently. Many HMDA fields are open to interpretation, and setting internal standards can prevent confusion, inconsistencies, and errors down the road. This session covers the gray areas HMDA doesn’t define and gives you practical tools to make those decisions, document them, and train staff.

Agenda

• Why HMDA compliance starts before you collect or report any data

• Application Date: common confusion points and best practices

• Action Taken Date: documenting and sticking to your internal policy

• Rate Set Date: key to getting Rate Spread and HOEPA right

• Credit Score: choosing the method, documenting reliance

• Clarifying relied-on fields in Adverse Actions and non-QM products