How will your institution avoid the perfect storm of annual HMDA reporting and ATR/QM implementation
With the Ability-to-Repay and Qualified Mortgage rule (ATR/QM) set to crash into our industry, we're wondering whether organizations are fully prepared to take care of HMDA in a timely manner, or whether they believe they can juggle both HMDA and ATR/QM at the same time?
We here at Spillane Consulting are hoping to receive more feedback on this issue from you, our clients. However, please let us share what we've heard so far.
Here are some tips on handling the next few months:
Be proactive with HMDA! Don't wait and try to handle HMDA at the same time that the ATR/QM mortgage rules are being implemented!
Get started on ATR/QM today! Not only will these new rules require training, systems updates, and new processes, it will also require serious business decisions to be made by your organization. Will you offer non-QM products? If so, which ones?
Unless your organization is large enough to have someone on your staff with adequate expertise and time to devote solely to these projects, consider partnering with a company like Spillane Consulting to get through these difficult months ahead.
Get a jump on these issues today. Remember the Chinese proverb, "The best time to plant a tree is 20 years ago. The second best time is today."
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**These are our opinions. We're not authorized, or willing, to express those of others.**