Independent Banker - October 2017 - 69

Risks & Rules
be implemented by the end of 2017
for banks to collect the expanded
data beginning Jan. 1, 2018. For
community banks, it is a massive
undertaking, probably on the level
of what the industry encountered to
implement TRID. "
Many of the new and revised
data points are not one-step " checkthe-box "
items and require some
calculation or comparison with other
information to produce the reportable
data. Haynie notes that banks
that will use loan origination systems
to conduct those calculations or
comparisons and feed the data into a
reporting system will rely on vendors
for software updates for those processes.
Many community banks are
still waiting for that software to be
ready, so they can implement it, test
it and train staff.
Due to the expansion and complexity
of the new rule, there is concern
for community banks that report
manually. Manual entry generally
lacks efficiency, is time consuming
and can lead to errors in reporting.
The Consumer Financial Protection
Bureau (CFPB) is creating a web
portal for manual data entry; however,
the portal is not yet operational,
which prevents banks from finalizing
processes and getting people trained.
Community banks should follow
some key steps to position themselves
for the new requirements.
" One of the first steps for community
banks should be to understand
whether the rule applies to them and
identify where the bank is in relation
to the type of transaction, asset
size and other thresholds for data
collection, " advises Barbara Boccia,
senior director, US advisory services
and regulatory relations, compliance
solution, with Wolters Kluwer. " As
the CFPB continues to tweak the
requirements, the landscape is evolving,
and community banks will need
to continuously monitor for changes
and use the most up-to-date sources
available in the months before the
Jan. 1, 2018 start date. " She also
notes the industry is waiting for
the CFPB platform and geocoder to
become available.
In the interim, according to Boccia,
community banks should be
evaluating " what's in and what's
out " for reporting. Which lines
of business must report? Which
procedural changes will be needed?
Who will be affected? Which
additional training requirements
might be needed for staff who are
new to HMDA data collection and
reporting? How might file documentation
procedures change for
some business lines? Where are the
control points on data collection
Further reading
View ICBA's HMDA summary
document at tinyurl.com/
HMDAsummary
___________
and reporting, and how might they
change with the new requirements?
Which policies, procedures and
training materials will need to be
revised? Will the bank use the CFPB
geocoding tool or the existing FFIEC
tool, and how might a change to that
process affect the bank's HMDA data?
Transactional coverage
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Independent Banker - October 2017

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