QuestSoft held a free webinar on September 7, 2017 focusing on the impact of expanded loan level data under the new CFPB HMDA rules and how it will affect fair lending analyses.
For the last decade fair lending compliance has meant monitoring and analyzing your publicly available HMDA data, as well as “HMDA Plus” or non-public data. The new risk is that expanded loan level data will now be available not only during an examination, but also to the public. Although it is still uncertain how much data will be publicly available, we can assume that sufficient data will be available to permit a more comprehensive fair lending analysis by examiners, community groups, media and consumers.
The new HMDA data also places the ability to do an automated fair lending analysis instantly in the hands of the examiner BEFORE they meet with you. Not only will regulators know if you're an outlier within minutes, but depending on the data the CFPB decides to make public, your competitors will also know your profit margins and pricing strategy
Topics for this webinar included:
- Increased regulatory and reputational risk, complaints, targeted community group focus, and renewed class action activity
- Expanded risk management efforts
- Changes in the examination process
- New demographic comparators for the identification of disparate treatment and disparate impact.
- Enhanced peer comparisons, identification of matched pairs, and new redlining risks
Managing Director, CrossCheck Compliance
Loretta is a managing director with responsibility for CrossCheck’s Fair Lending practice which includes fair lending, HMDA, and CRA. Loretta is a regulatory compliance and risk management executive with over 30 years of experience in the financial services industry. Her most significant area of focus is fair and responsible lending risk management, including compliance management system and program development, qualitative and quantitative risk assessments, data quality management, process mapping, and staff training.
President, QuestSoft Corporation
Leonard Ryan has been associated with the mortgage industry for over 30 years, and is the founder of QuestSoft. He is a member of both MBA HMDA and NMLS Mortgage Call Report working groups, and is nationally recognized as a HMDA expert.