CFPB Sues Large Non-Depository - Let SCA Relieve Compliance Stress & Simplify HMDA Reporting for You!
Written by: Bill Dolan, Director, CMB, AMP
The CFPB filed yet another complaint this past week against a large non-depository mortgage company, alleging “widespread and significant errors” in their 2020’ HMDA data. This comes after a 2019’ consent order based on alleged RESPA section 8 violations in August of this year, imposing a $1.75 million civil money penalty for giving or receiving things of value for referrals of mortgage and settlement service business.
In this lawsuit against the company, the CFPB has alleged the company’s HMDA data errors included the following:
Improper classification of certain loan applications identified as “approved but not accepted” that had been withdrawn, which naturally caused errors in other related data fields.
Input data errors related to subordinate lien loans and purchased loans.
Loans reported in HMDA that did not meet the HMDA definition of reportable application.
Inaccurate calculations of rate speed, causing errors in other related data fields.
Inaccurate purchaser type on tens of thousands of loans; and
Inaccurate data reported for lender credits.
The lawsuit is the third enforcement action by the CFPB against this company, which demonstrates just how seriously the CFPB takes the accuracy of data, whether first-time or “repeat offenders”. Although this particular lawsuit does not appear to involve race, ethnicity, or sex information, the CFPB sees HMDA enforcement as a major part of its Fair Lending mission.
And what about you? Just where does your HMDA LAR stack up when it comes to data integrity and input? As a lender, you must ensure that your policies and procedures ensure accurate reporting of HMDA data.
If you aren’t comfortable with the HMDA data you intend to submit to the CFPB on March 1, 2024’, NOW is the time to contact SCA’s HMDA Compliance consulting team of industry experts to reduce the stress, making your LAR submission as worry-free as possible.
SCA will analyze (full or partial scrubs of 25%) of your monthly data (residential, HELOCs, or commercial real estate loans) by:
Identifying and correcting errors on multiple data fields concurrently; reviewing and comparing each HMDA data entry on your LAR to the loan documents viewed through “audit access” found within your LOS system eliminating reporting errors prior to the HMDA LAR submission.
Furthermore, SCA’s HMDA consultants (with decades of compliance and lending experience) realize that training is an integral part of the HMDA review and reporting process.
Does your team need a refresh based on prior or upcoming HMDA results or exams, changes in personnel, or just some updated training for existing staff due to the current changes implemented by the CFPB?
At SCA, our team will help prepare your staff to “Get It Right” as stated by the CFPB by participating in our comprehensive HMDA training program that includes HMDA technical reporting, industry best practices, and/or customized training if requested to meet you and your company’s needs.
By outsourcing this function, SCA can and will eliminate the stress and worry not to mention the excessive amount of time and expense required in analyzing, identifying, and reducing HMDA errors, providing you with a clean and accurate LAR, ready for submission.
Do yourself a favor and contact Bill Dolan, Director at (617) 694-2617 or at Wdolan@scapartnering.com to hear more about SCA’s HMDA Review services, and while you’re at it, take a look around our website to learn more about our full array of consulting and fulfillment services.
