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Home Mortgage Disclosure Act (HMDA)

The contents of this announcement will not cover all the HMDA rule changes in its entirety and will focus on the aspects that may alter how you deliver loans to Flagstar.

The Consumer Financial Protection Bureau issued a final rule amending Regulation C. HMDA requires certain financial institutions to collect, record, report, and disclose information about their mortgage lending activity. The final rule changes:
  • The types of financial institutions that are subject to Regulation C
  • The types of transactions that are subject to Regulation C
  • The data that financial institutions are required to collect, record, and report
  • The processes for reporting and disclosing HMDA data
Most provisions of the rule go into effect on January 1, 2018 and apply to data collected in 2018 and reported in 2019 or later. An institutional coverage change for depository institutions was effective January 1, 2017. Please refer to the HMDA Key Dates Timeline from the CFPB for the effective dates.

For data collected in or after 2018, the HMDA rule amends the requirements for collection and reporting of information regarding an applicants or borrower’s ethnicity, race, and sex. The CFPB published a Sample Data Collection Form that provides the required aggregated categories and disaggregated subcategories for ethnicity and race. LendingSpace will be updated to include the additional data required as displayed on the Sample Data Collection Form beginning on January 1, 2018.

The following will be required when delivering loans to Flagstar:
  • Lenders must provide Flagstar with the Universal Loan Identifier (ULI) on each transaction. The ULI must begin with the lenders Financial Institution Legal Entity Identifier (LEI), followed by up to 23 additional letters and/or numbers that the lender assigns, and end with a two-character check digit. The ULI must be used for only one application/loan and cannot be re-used. Lenders may visit the Global LEI Foundation website to obtain an LEI.

  • For any delegated transaction purchased by Flagstar, Flagstar will report the loan as a purchase for HMDA purposes upon loan funding, however it is the correspondent’s responsibility to also report on loans in which the correspondent makes the credit decision.
More detailed information will be provided as we approach the effective date.

LendingSpace System Enhancements

The following changes are now available in LendingSpace:

  • Qualifying FICO field will now allow “0” to be entered for non-traditional products
  • UFMIP Financed field available on conventional loans with financed or single premium MI
  • Enhanced data fields on locking screens allow you to include the Census Tract and FIPS information
  • Loan Category field added with new product codes to identify HomeReady and HomePossible products
  • Ability to upload UCD XML files in a separate document from the Credit/Closing package. A separate field is available in the Doc Center to specify your UCD in XML format
If you have any questions, please contact your sales relationship manager.

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