Compliance Central: Preparing for HMDA - Do You Have a Legal Entity Identifier?

As credit unions approach the Jan. 1, 2018, implementation date for new Home Mortgage Disclosure Act requirements, getting all the pieces in place is a challenge. For any loan on which the credit union takes "final action" on or after Jan.1, credit unions that report will be subject to the many new data points in revised HMDA.

One of these new data points will be the "universal loan identifier," which will specifically identify a covered loan or application with a unique number consisting of several components. One component refers to the credit union itself - the "Legal Entity Identifier," or LEI. Credit unions subject to HMDA reporting that do not already have an LEI will need one to be in compliance.

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From the May-June 2017 edition of The NAFCU Journal magazine.