In addition to improving data quality and streamlining the reporting process, the CFPB is considering implementing SAAS to facilitate the reporting process. AppraisalPro is currently integrated with TrakLogix, an SAAS platform.
The CFPB is proactively aiming to improve reporting of loan application activity, HMDA, their goal is to improve data quality and streamline the reporting process. If you read our last blog (Analysis of HMDA data) – you would know that if a lender were to stream line their loan approving process, they could greatly increase revenue.
Once there is improved quality of these data, it will help regulators evaluate credit ability, and reporting process optimization will help save time. The CFPB plans to get feedback on its proposed changes from small businesses.
The Dodd-Frank Act requires the CFPB to expand HMDA. Due to credit shortages, HMDA was enacted in 1975 and required reporting of loan applications for institutions that issue at least 100 loans a year. The Reporting concerns 1-4 unit and multifamily properties.
Expanded data requirements prescribed by the Dodd-Frank act includes:
- Total points and fees, and rate spreads for all loans
- Riskier loan features including teaser rates, prepayment penalties, and non-amortizing features
- Lender information, including a unique identifier for the loan officer and the loan
- Property value and improved property location information
- Age and credit score
The additional data proposed by the CFPB from its own initiative includes:
- Mandatory reporting of denial reasons
- Debt-to-Income (DTI) ratio
- Qualified Mortgage status of loan
- Combined loan-to-value (CLTV) ratio
- Automated underwriting systems results (for example, FHA’s Total Score system)
- Additional points and fees information
- Total origination charges
- Total discount points
- Risk-adjusted, pre-discounted interest rate
- Interest rate
- Affordable housing programs
- Manufactured housing data
The CFPB would ultimately like to institute this reporting as a standard to the currently established data collected processes of most financial institutions. In addition to this, the CFPB is considering lowering the required reporting institutions from 100 loans a year to 25 loans a year. The CFPB is considering implementing SAAS to facilitate the reporting process.