Is There a FastPass to HMDA?

About a year ago, my husband and I decided to plan a trip to Disney World in Orlando, taking our four-year-old daughter. If you have ever been to a Disney Theme Park, you know that the cast, crew, and Imagineers offer wonderful opportunities for families to create lifetime memories. We don’t travel a lot, but we knew that to make the most of the Disney Experience, planning would involve much more than simply going online to make flight and hotel reservations. Aside from the expected wide array of lodging options, there were the challenges of learning about everything from Character Experiences to Dining Plans, FastPass+ to Magic Bands, and the list goes on. Disney does an excellent job of reminding you to book your dinner reservations 180 days in advance, reserve your FastPass selections 90 days in advance, and sync your Magic Bands 30 days in advance. Even with all of the advanced preparation, an unexpected hurricane nearly caused us to cancel the entire trip. But we were lucky, and our flight took off on time, one day after the hurricane. In the end, our efforts paid off, resulting in having the time of our lives as we made our dream vacation a reality.

Upon returning to work after our vacation, a bank client approached me with concerns about dealing with upcoming HMDA revisions. While the timeline for HMDA revisions under the final rule spans from 2016 through 2020, many provisions kick in on January 1, 2018. These include provisions related to institutional and transactional coverage, data collection, recording, reporting, and disclosure. Coverage is being expanded to most dwelling-secured loans, and there will be 25 new data fields as well as revisions to several existing fields. That’s more than just a few tweaks here and there; it is a major overhaul.

My family’s Disney trip would not have been a success without a carefully planned implementation strategy, checks and double-checks, and follow-up. And sadly, there is no Magic Kingdom FastPass+ for HMDA. For bankers who are impacted, it is time to meticulously plan by developing an implementation strategy that will encompass those changes needed 12 months in advance, 180 days in advance, 90 days in advance, and so on. While Wipfli can’t offer a poof of fairy dust and make everything ready with the tap of a wand, we welcome the opportunity to hear your concerns and offer input on strategies to help you achieve this transition. We offer training on the new provisions and implementation assistance. To learn more, please contact your Wipfli relationship executive or send an email to WipfliFIPractice@wipfli.com.