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HMDA, hmmm? Reporting data points as “not applicable”

first_img ShareShareSharePrintMailGooglePinterestDiggRedditStumbleuponDeliciousBufferTumblr Like many of you, I have been busy, busy, busy attending NAFCU’s Virtual Regulatory Compliance School. The virtual experience was new for me (and I bet most of you), but the conference was a great success. I learned so many new things, but studying to be an NCCO is no easy task. However, after many long evenings of studying, I get to update my signature line to: Janice Ringler, NCCO!Congratulations and welcome to all the new NCCOs!On July 28, 2020, CFPB released its fourth update to its HMDA FAQs, updating question #7 in the Ethnicity, Race, and Sex section, and questions #1 and #2 in the Multiple Data Points section. The FAQ’s attempt to clarify when combined loan-to-value (CLTV), debt-to-income ratio (DTI), income, and property value needs to be reported on the LAR.  The FAQs state that all of these fields must be reported “if they were a factor relied on in making a credit decision—even if the data was not the dispositive factor.” The FAQs set a “relied on” standard to determine when the credit union must report the data for income, credit score, DTI, CLTV, and property value. However, Regulation C allows credit unions to report these data points, along with credit score and credit score model, as “not applicable.” A frequent question we get from credit unions is:If these data points must be reported if they are “relied on in making a credit decision”, in what instances would these fields be reported as “not applicable?” I have explored some possible scenarios below. continue reading »last_img read more

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Stars stunned by Arizona weather

first_img Like the other 63 players in the Accenture Match Play Championship, Poulter was back at Dove Mountain near Tucson for the resumption of a first round halted by the wintry conditions. Less than four hours’ play was possible and 10 games – including those of top seeds Rory McIlroy, Tiger Woods and Luke Donald – did not even tee off. “This weather is officially ridiculous,” McIlroy, who plays Shane Lowry in one of two all-Irish clashes, said on Twitter. The other one between Graeme McDowell and Padraig Harrington had only just started when the suspension came and McDowell commented: “Holy coldness. I’ve only ever played in an event with conditions like this once.” It was the West of Ireland Championship in “about 1998”. Poulter, winner in 2010 and perhaps the most feared match play golfer around after his deeds at the Ryder Cup, was going well. He stood three up on Scot Stephen Gallacher, who three-putted the short sixth and conceded the eighth and 10th. “What’s the problem? Let’s play,” Poulter joked on Twitter. “The caddies have officially just had a snowball fight. Never seen anything like it.” He then posted a picture of “at least two inches of snow” on his courtesy car. Lee Westwood was two up on Spaniard Rafael Cabrera Bello after five and Justin Rose two up at the turn on South Korean KJ Choi, although he had been four up after five. Welshman Jamie Donaldson, winner of last month’s Abu Dhabi Championship, had to take a penalty drop after his opening drive and bogeyed five of the first seven holes to be three down to Thorbjorn Olesen, but Bristol’s Chris Wood, who won his first European Tour title a week later in Qatar, was level with Masters champion Bubba Watson after six. Closest to winning was Sergio Garcia, whose first shot on his return will be a 12-foot putt to beat Thailand’s Thongchai Jaidee on the 16th green. The forecast was for the snow to have cleared away overnight, but there was the possibility of early frost and that would delay things further. Ian Poulter has never seen anything like it – caddies having a snowball fight in the Arizona desert.center_img Press Associationlast_img read more

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Bumper weekend of club hurling ahead

first_imgSpeaking to Tipp FM Sport Kildangan manager Dan Hackett said his team have underachieved in Semple Stadium over the last few years. The North champion’s manager believes its time to take the opportunity that presents itself. Two hurling double headers take place in Semple Stadium On Saturday the tie of the round sees North champions Kildangan meet Drom Inch at 2pm while at 3.30 Three in a row West winners Eire Óg Annacarthy meet Kilruane McDonaghsOn Sunday Portroe and Nenagh meet at 2pm while Thurles Sarsfields meet Clonoulty Rossmore at 3.30.last_img read more

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