6/29/2017

HMDA After January 2018

In 2018, the reporting requirements  extend to more mortgage transactions. Today 2017 June, the HMDA reporting requirements apply only to closed-end home purchase and home improvement loans and refinances.
As of January 1, 2018, the following loan types will be subject to reporting requirements:
  • Closed-end home purchase loans
  • Closed-end refinances
  • Closed-end home improvement loans
  • Open-end mortgages
  • Home equity lines of credit
  • Reverse mortgages
(12 C.F.R. §1003.2(e))

The applicability of HMDA and Regulation C does not depend on the use of a home as a principal dwelling.  Therefore, even loans that are secured by second homes, vacation homes, or rental properties are subject to the law (Official Interpretations to 12 C.F.R. §1003.2(f), 1.).  Simply stated, HMDA applies to all dwelling-secured loans, and amended Regulation C broadly defines the term “dwelling” to include most residential structures, including detached homes, individual condominium or cooperative units, manufactured homes, multifamily structures, and multifamily communities (12 C.F.R. §1003.2(f)).

Small companies must comply, keep records and report.
Seems like small mortgage banking or brokerages must hire legal
staff to keep up with the law

Exempt  from HMDA’s reporting requirements:
  • Loans secured by unimproved or vacant land, unless the lender knows that loan proceeds will be used within two years of closing to construct a dwelling
  • Construction loans or bridge loans
  • Loans for less than $500
  • Loans secured by property used for agricultural purposes
  • Loans secured by property used primarily for business or commercial purposes

Other exemptions include transactions for the purchase of servicing rights to a loan, mortgage loans acquired through mergers and acquisitions, and the purchase of mortgage-backed securities. These exemptions are currently scattered throughout the regulations, but the new rules that are effective in 2018 place the HMDA exemptions in Section 1003.3(c) of Regulation C.

Data Collected for HMDA Reporting until December 2017


  • Loan information:
    • An identifying number for the loan or loan application
    • The purpose of the loan (home purchase, refinancing, home improvement)
    • Lien status
    • An indication of whether the related dwelling is owner-occupied
    • Loan type (conventional, FHA, VA)
    • Type of dwelling securing the loan (one- to four-family dwelling, multifamily dwelling, manufactured home)
    • Loan amount
    • Application date
    • Action taken on the loan (approval or denial) and date the action is taken
  • Location of the property related to the loan application
  • Demographic information about the applicant (gender, race, ethnicity, and gross income)
  • Loan purchase information
  • Loan pricing information (used to identify reverse redlining)
  • Denials for pre-approval requests and information on approvals that led to loans 

  • 2018,  data collection categories, consisting of the current plus the new categories:
    • Identifiers for loans and lenders: A universal loan identifier made up of 45 alpha-numeric characters will identify the loan or loan application, and a 20-character alpha-numeric code will identify the financial institution involved in the transaction.
    • Underwriting information: The information related to underwriting will include the loan applicant’s credit score, credit scoring model, LTV ratio, DTI ratio, property value, and reason(s) for denying a loan application.
    • Demographic information: In addition to information already reported, loan originators must report an applicant’s age and must offer applicants the option of providing more details on their race and ethnicity.
    • Loan terms and pricing: New rules require the reporting of a loan’s (or a proposed loan’s) APR, difference between the APR and average prime offer rate, loan costs, points, lender credits, amounts disclosed as borrower-paid, interest rate, prepayment penalty provisions, loan term, number of months between origination and rate changes for ARMs, interest-only payments, balloon payments, and any payment provisions resulting in negative amortization.
    • Property information:  address, census tract, value of the property, and its use as a residence, second home, or investment property.
    • Identification of loan originator: Data reported for each transaction must include the NMLS unique identifier of the mortgage loan originator who provided loan origination services for the loan or application.
    • Disposition: Lenders must report approvals, denials, and an applicant’s withdrawal of an application. Denials of requests for preapprovals are also reported, and even if an approval does not lead to the origination of a mortgage, the approval must be reported.
    • Loan application channel: Lenders must indicate whether a consumer submitted an application directly to a lender or to a mortgage broker.
    (12 C.F.R. §1003.4(a))
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HMDA
















HMDA
Banks and small lenders now monitored by the CFBP
The first step in determining whether a financial institution must comply with HMDA is to establish whether it has a home or branch office in an MSA. Institutions that only operate outside of an MSA are not subject to the law’s data collection and reporting requirements. For example, a financial institution that exclusively serves rural areas is not subject to HMDA.
Financial institutions that are located in an MSA are subject to HMDA requirements if they meet established thresholds. Historically, depository and non-depository institutions have been subject to very different loan-volume and asset-size thresholds, but beginning on January 1, 2018, there will be a uniform loan-volume threshold for both types of institutions.
The new loan-volume threshold for depository and non-depository institutions is:
  • The origination of at least 25 closed-end mortgage loans in each of the two preceding calendar years, or
  • The origination of at least 100 open-end lines of credit in each of the two preceding calendar years
(12 C.F.R. §§1003.2(g)(1)(v), (g)(2)(ii))

If a non-depository institution meets the loan-volume threshold and had a home or branch office in an MSA on the preceding December 31, it is subject to the data collection and reporting requirements of HMDA. As previously mentioned, in 2018, there will no longer be an asset-size threshold for non-depository institutions (12 C.F.R. §1003.2(g)(2)).

If a depository institution meets the loan volume threshold and home or branch office in an MSA on the preceding December 31, it is subject to HMDA if it also:
  • Meets an annually-adjusted asset-size threshold (this threshold will allow small banks and credit unions to escape the burden of HMDA data collection and reporting requirements)
  • Originated at least one home purchase loan or refinance of a home purchase loan in the preceding calendar year, and
  • Meets one or more:
    • It is a federally insured or regulated institution (e.g. it is an FDIC bank or a Federal Reserve bank)
    • It makes federally insured or guaranteed loans (e.g. FHA loans or VA loans), or
    • It makes loans intended for sale to Fannie Mae or Freddie Mac

(12 C.F.R. §1003.2(g)(1))












Concern for the decline of urban neighborhoods was a significant factor that led to HMDA’s enactment.  The law and its requirements continue to focus on lenders that are located in metropolitan statistical areas (MSAs).  An MSA is an urbanized area with a population of at least 50,000, which includes an urban center and surrounding areas that are economically and socially tied to it.  The Office of Management and Budget uses census data to identify MSA
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6/23/2017

Get your Offer Accepted and Sit Pretty



You know the basics: sit come, and down for dog training 
 but Real Estate is not that simple. In this Seller's Market it
is difficult to get your offer accepted. Here's a list of strategies to get into your next home.
Simple commands to get Seller to Accept your offer:

Know the location and market you are shopping in advance. I can share Home Scouting app

https://hbsr.homescouting.com/SignIn   password is 9497849699




 
  1. Get in ASAP to view the property, before broker preview. Be respectful and quiet while walking through the home, take notes, or images. Discuss with your agent in the car.
  2. Write thank you note to listing agent addressed to seller 
  3. Get clean offer in immediately with every line exact
  4. Make your highest and best offer first without a list of requests
  5. Have loan pre-approval from lender who can close in 20 days. Write the contract with 7 day contingencies. Make sure lender writes that they can complete appraisal in 7 days ad final approval in 10 days. Get your paperwork in to lender BEFORE making offers.  You agent can note that if seller needs more time to rent back, that may be possible
  6. Large earnest money deposit
  7.  Show large down payment, cross out account numbers
  8. Write a personal letter about why you love this house the details why it suits your needs

Work with local agent who is well respected and lender also who is respected.
Your auntie from 200 miles away may not have the clout that a buyer's agent in the neighborhood has. Same with lender, an online lender or big box bank may not close on time


Want apply to get you loan pre- approved?

Call me (949) 784- 9699
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 | Equal Housing Lender | NMLS 324982
| Company NMLS # 1775393 - 
Licensed by the California Department of Business Oversight under the California Financing Law, 
License #60DBO89397 
and the Department of Real Estate, License #02083817. Licensed by the WA State Department of Financial Institutions under the Consumer Loan Company License, #CL-1777393. Licensed by Oregon Division of Financial Regulation under the Oregon Mortgage Lending License, #ML-5873. Licensed by the Colorado Division of Real Estate Commission, Colorado Mortgage Company Registration.
  
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6/02/2017

Win $1000 Easy Peasy

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