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The CFPB recently issued a report entitled Data Point: Asian American and Pacific Islanders in the Mortgage Market. The report briefly examines differences among subgroups of Asian American and Pacific Islanders (AAPI) based on the 2020 Home Mortgage Disclosure Act (HMDA) data. In issuing the report the CFPB stated that “[e]xisting studies often portray AAPI borrowers as similar in characteristics to non-Hispanic White borrowers and thus imply that the group fares well.… Continue Reading

In connection with the release of its latest semi-annual regulatory agenda, the CFPB announced that it will assess the October 2015 significant amendments to Regulation C under the Home Mortgage Disclosure Act (HMDA), and that it will not pursue other HMDA rulemakings.

The Dodd-Frank Act requires that the CFPB conduct an assessment of each significant rule or order it has adopted under federal consumer financial law and publish a report of each assessment no later than five years after the effective date of the rule or order.… Continue Reading

Almost 45 years after the FTC’s Holder Rule and corresponding FTC staff guidance were issued, the FTC has issued a “staff note” in which FTC staff concludes that the TILA exemption for large transactions does not apply to the FTC’s Holder Rule (which is officially titled the “Trade Regulation Rule Concerning Preservation of Consumers’ Claims and Defenses”). … Continue Reading

The CFPB recently announced the public availability of calendar year 2020 residential mortgage loan application data reported under the Home Mortgage Disclosure Act (HMDA). The data can be accessed here. For each reporting institution, a modified version of the HMDA data reported by the institution is made publicly available. For privacy reasons, certain reported data is removed or modified before it is made public.… Continue Reading

The Federal Financial Institutions Examination Council (FFIEC) recently issued the 2021 edition of A Guide to HMDA Reporting (Guide). The Guide addresses the collection and reporting of residential mortgage loan application data under the Home Mortgage Disclosure Act (HMDA) for calendar year 2021.

The Guide reflects the changes to the HMDA reporting thresholds that the CFPB adopted in April of 2020.… Continue Reading

Although HMDA reporting institutions are busily working on their submission of 2020 data, the CFPB recently announced the availability of a beta version of the HMDA reporting platform for 2021 data. (As previously reported, in early January 2021 the CFPB announced the availability of the platform for the submission of Home Mortgage Disclosure Act (HMDA) data collected in 2020.)… Continue Reading

The CFPB recently announced that the platform for the submission of Home Mortgage Disclosure Act (HMDA) data collected in 2020 is now available for the submission of the data. The platform may be accessed here. HMDA data for 2020 must be submitted on or before March 1, 2021.

A beta testing version of the platform also is now available and may be accessed here.… Continue Reading

The CFPB recently issued a final rule increasing the asset exemption threshold under the Home Mortgage Disclosure Act (HMDA) and a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA) requirement to maintain an escrow account for a higher-priced mortgage loan.

Banks, savings associations, and credit unions are not subject to HMDA for a calendar year if their assets as of December 31, of the prior calendar year did not exceed an asset threshold.… Continue Reading

As previously reported, in August 2020 the CFPB released the Home Mortgage Disclosure Act (HMDA) Filing Instruction Guide (FIG) for data that must be collected in 2021 and reported in 2022. Recently, the CFPB released an update to the FIG. Edits Q656 and Q657 that were in Table 8: Macro Quality Edits for Loan/Application Register of the prior version of the FIG have been reclassified and moved to Table 7: Quality Edits for Loan/Application Register in the updated version of the FIG.… Continue Reading

The CFPB recently announced that it, along with the Comptroller of the Currency and Federal Reserve Board, issued a final rule that will maintain the current exemption threshold to the appraisal requirement for higher priced mortgage loans (HPML). The initial exemption threshold was $25,000, and the threshold is subject to annual adjustment based on changes in the Consumer Price Index for Urban Wage Earners and Clerical Workers.… Continue Reading