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is Bank Management
report those TRID fields “if the revised Closing Disclosure was
provided to the borrower during the same reporting period in
which loan closing occurred. Comment 4(a)( 17)(i)- 3.” Home
Mortgage Disclosure (Regulation C) – Small Entity Compliance
For those institutions that promptly pull their LARs at the
end of every month or quarter, you must build processes to
identify the loans with revised Closing Disclosures so that the
most recent data is re-pulled and reported on the LAR.
4. Operationally Difficult Fields (A.K.A., the “Why
the H-E-double-hockey-sticks would I ever give
you this information after you just declined me?”
Examples of fields impacted (there are numerous):
■ ■ ■ Manufactured housing related fields (as determined by response to Construction Method question)
• Manufactured Home Secured Property Type
• Manufactured Home Land Property Interest
Here’s a brief scene from a movie script I’m writing (my
working title is, “A Terrible Consumer Experience” and we’ve
penciled in Brad Pitt as the lead):
Loan Officer: Sorry Mr. Borrower, we don’t offer loans secured by manufactured homes here at Enormo Bank.
Borrower: Oh my goodness, now what am I going to do? I
was just ready to put in an offer.
Loan Officer: Sounds like you’re kind of screwed there.
Hey, while I have you on the line can you tell me how your
proposed manufactured home was going to be secured?
Was it “Manufactured home and land” or “Manufactured
home and not land”?
Also, tell me about your proposed property interest in
the land? “Direct ownership,” “Indirect ownership,” “Paid
leasehold,” or “Unpaid leasehold”?
I can’t imagine a consumer willingly giving this information to a lender after they’ve been declined. So we’re left with a
couple of options:
1. Ask all of the manufactured home information before you
tell a consumer you can’t do the loan for them—and risk the
consumer’s ire for all of the unnecessary questions (“Thanks
so much for all of that detailed information on the loan we
couldn’t do for you! Sorry again that we couldn’t do your
loan. Please make sure to give us all 5s on our survey and
make it a great day!”); or
2. Ask basic “gating” questions up front before you have a
HMDA application to avoid these ancillary questions—
while making sure to provide an adverse action for required
Regulation B/ECOA declines.
In both scenarios the borrower is declined, but at least in
Scenario 2 you’re minimizing the borrower’s wasted time.
We’ve gone through four of these hidden speed traps, but there
are others. Spend some time thinking about the implications of
operationalizing the new rules. For example, look for traps: