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Tag Archives: HMDA

New CFPB webinar available on 2015 HMDA final rule

Posted in Mortgages

On October 15, 2015, the CFPB released a final rule amending Regulation C, which implements the Home Mortgage Disclosure Act (HMDA), requiring certain data on mortgage applications and loans to be collected beginning in 2017 by “covered institutions.” The CFPB has previously made various resources available for HMDA filers, including a recording of a webinar… More >

Updated HMDA resources for data collected in 2017 and 2018

Posted in CFPB General, CFPB Rulemaking

As we have previously discussed, on October 15, 2015, the Consumer Financial Protection Bureau (CFPB) released a final rule amending Regulation C, which implements the Home Mortgage Disclosure Act (HMDA), requiring certain data on mortgage applications and loans to be collected in 2017 by “Covered Institutions.” The 2017 HMDA institutional chart  provides guidance on how… More >

CFPB announces annual adjustments to HMDA/TILA asset-size exemption thresholds

Posted in Mortgages

The CFPB has announced annual adjustments to two asset-size exemption thresholds.  First, the CFPB has made no change to the asset-size exemption threshold under HMDA/Regulation C which is currently set at $44 million.  Banks, savings associations, and credit unions with assets at or below $44 million as of December 31, 2016 will continue to be… More >

CFPB sending HMDA warning letters

Posted in Mortgages

The CFPB announced that it is issuing warning letters to 44 mortgage lenders and mortgage brokers stating that it “has information that appears to show that your company may not be in compliance with certain provisions of the Home Mortgage Disclosure Act (HMDA) and its implementing regulation, Regulation C.” According to the CFPB’s press release, the… More >

CFPB approves FHLMC/FNMA revised uniform residential loan application; collection of HMDA ethnicity and race information in 2017

Posted in Mortgages

In a notice published in today’s Federal Register, the CFPB announced that it has given its “official approval” to a revised and redesigned Uniform Residential Loan Application (2016 URLA) and to the collection of expanded Home Mortgage Disclosure Act information on ethnicity and race in 2017. 2016 URLA.  The 2016 URLA approved by the CFPB… More >

HMDA resources for data collected in 2017 and 2018

Posted in CFPB General

As we have reported, the Consumer Financial Protection Bureau (CFPB) released a final rule amending Regulation C, which implements the Home Mortgage Disclosure Act (HMDA), requiring “Covered Institutions” to report certain information about mortgage applications and loans in efforts to create transparency in the mortgage lending process. In connection with the revisions, beginning with data… More >

CFPB engaged in process to allow public input on privacy questions under new HMDA rule

Posted in Mortgages

On January 11, Elena Babinecz, a CFPB attorney, spoke as part of a panel relating to the revised HMDA rule at the Winter Meeting of the Consumer Financial Services Committee of the Business Law Section of the American Bar Association.  Ms. Babinecz confirmed that the CFPB is engaged in a follow-up policymaking process to allow the public to… More >

CFPB seeks input on HMDA resubmissions

Posted in Mortgages

The CFPB has issued a request for information (RFI) seeking information on what changes to the CFPB’s HMDA Resubmissions Guidelines may be appropriate.  The RFI responds to comments received by the CFPB in connection with its final HMDA rule issued in October 2015 that it consider changes to the Resubmission Guidelines to reflect the expanded… More >

CFPB releases HMDA Rule Compliance Guide

Posted in CFPB Rulemaking, Fair Lending, Mortgages, Uncategorized

The CFPB released the Home Mortgage Disclosure (Regulation C) Small Entity Compliance Guide  on December 1, 2015.  According to the CFPB, the purpose of the Compliance Guide is to provide an accessible summary of Regulation C, in light of the final rule amending the Home Mortgage Disclosure Act (HMDA) which we summarized here.  In addition,… More >

Final HMDA rule makes significant changes

Posted in CFPB Rulemaking, Mortgages

As we previously reported, the CFPB has issued a final rule amending Regulation C, which implements the Home Mortgage Disclosure Act.  The final rule makes many significant changes, including changes to the rule’s coverage and the data that covered institutions must collect and report.  For a detailed discussion of the final rule, see our legal alert.

CFPB issues final HMDA rule

Posted in CFPB Rulemaking, Mortgages

The CFPB has issued a final rule amending Regulation C, its Home Mortgage Disclosure Act regulation.  The changes, which, in part, implement the Dodd-Frank Act’s amendments to HMDA, expand the scope of data required to be collected and reported, change the scope of HMDA’s coverage of both institutions and transactions, and adopt new processes for… More >

CFPB adjusts HMDA/TILA asset-size exemption thresholds

Posted in Mortgages

Adjustments to two asset-size exemption thresholds were published by the CFPB in today’s Federal Register.  First, the CFPB has increased the asset-size exemption threshold under HMDA/Regulation C which is currently set at $43 million.  Banks, savings associations, and credit unions with assets at or below $44 million as of December 31, 2014 are exempt from… More >

Leading industry trade groups comment on HMDA/Reg. C proposal

Posted in CFPB Rulemaking, Mortgages

Six leading industry trade groups have submitted a letter commenting on the CFPB’s proposed rule amending Regulation C to expand Home Mortgage Disclosure Act data reporting requirements.  The trade groups consist of the Consumer Bankers Association, Mortgage Bankers Association, American Bankers Association, Consumer Mortgage Coalition, Financial Services Roundtable and Housing Policy Council. In the letter,… More >

HMDA proposed rule published in Federal Register

Posted in CFPB Rulemaking, Mortgages

The proposed rule amending the Home Mortgage Disclosure Act and its implementing regulation, Regulation C, was published in the Federal Register today. As such, the official comment deadline will be October 29, 2014. We previously published a short description and analysis of the proposed rule that noted a different comment date. Our Mortgage Banking Group… More >

NCRC white paper seeks expansive CFPB rulemaking on small business lending data collection

Posted in CFPB Rulemaking, Fair Lending

The National Community Reinvestment Coalition (NCRC) has issued a white paper that urges the CFPB to take an expansive approach in developing regulations on the collection of small business lending data to implement Section 1071 of Dodd-Frank.  Section 1071 amended the Equal Credit Opportunity Act to require financial institutions to collect and maintain certain data… More >

CFPB adjusts HMDA data collection and TILA mortgage escrow thresholds

Posted in Mortgages

In notices published in yesterday’s Federal Register, the CFPB adjusted the thresholds of the asset-size exemptions for collecting HMDA data and establishing an escrow account for certain mortgage loans under TILA. Pursuant to Regulation C, which implements HMDA, depository institutions with assets below an annually adjusted threshold are exempt from HMDA data collection requirements. In… More >

CFPB ramps up enforcement of HMDA

Posted in CFPB Enforcement, CFPB General, Fair Lending

The CFPB announced on October 9, 2013 that they entered into consent orders with two financial institutions that allegedly misreported HMDA data.  The CFPB also issued Bulletin 2013-11, which provides guidance on compliance with HMDA, when the CFPB will pursue HMDA enforcement actions, and resubmission of HMDA data. According to the consent orders and the… More >

Use of HMDA data may lead to increase in enforcement actions and litigation

Posted in CFPB General, Fair Lending, Mortgages

The CFPB announced yesterday the release of both the 2012 Home Mortgage Disclosure Act (HMDA) data and a new web-based tool to access that data. In both Director Cordray’s remarks and the blog post, the CFPB appeared to indicate that HMDA data may be used to identify institutions that may be discriminating against protected classes of… More >

Fair lending gets attention

Posted in Fair Lending

The CFPB doesn’t want its fair lending authority to be in doubt. A recent blog post by Patrice Ficklin, the CFPB’s Assistant Director for the Office of Fair Lending & Equal Opportunity, describes the CFPB’s authority under the ECOA and HMDA and the “many tools” Ms. Ficklin’s office can use “to protect consumers from credit… More >

“Debugging” Version 1.0

Posted in CFPB General

The CFPB is to be commended for so quickly making public the first edition of its Supervision and Examination Manual, which it has referred to as “Version 1.0.” Unfortunately, though, as is often the case with Version 1.0 of anything, the Manual would have benefitted from a more thorough debugging prior to its release.  Not… More >