By Gina Ellis
In our blog post September 6, 2016, we discussed the revised Uniform Residential Loan Application Form (URLA). While the CFPB officially issued its approval of the form, Fannie Mae and Freddie Mac (the GSEs) have indicated the form should not be used until they establish final effective and mandatory compliance dates. So, what does that mean for you?
We recommend you continue to use the current URLA until the GSEs issue further guidance and implementation timelines. If you are a HMDA reporter, you may consider using the new Demographic Information Addendum sometime in the fourth quarter 2017. This addendum was issued with the amendments to Regulation C for the collection of expanded race, sex and ethnicity categories and subcategories you will be required to report for HMDA purposes beginning in 2018. This addendum can be used with the current URLA by crossing out or shading the monitoring information in Section X of the current form.
There could be situations in the fourth quarter of 2017 where you will accept an application but the final action will not be taken until 2018. In these situations, you will have an option to report the government monitoring information as you currently do or use the new categories and subcategories. Either way, you should begin training applicable personnel regarding the new form and reporting categories in 2017.
You can find our September blog post here: https://www.americanbanksystems.com/redesigned-uniform-residential-loan-application-form/
Additional links to the addendum and GSE statement can be found here:
https://www.fanniemae.com/content/guide_form/urla-demographic-addendum.pdf
https://www.fanniemae.com/content/news/urla-announcement-november-2016.pdf
As always, we are here to help! Stay connected with us and we will provide additional information to assist you with these changes. www.americanbanksystems.com or call us at (405) 607-7000.
