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 (HPML). 

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

The CFPB recently issued a technical rule to reinstate the closed-end loan reporting threshold under the Home Mortgage Disclosure Act (HMDA) of 25 originated covered loans in each of the prior two calendar years that was adopted in an October 2015 rule. The technical rule will be effective on the date that it is published in the Federal Register.… Continue Reading

In a recent blog post, the CFPB addressed its approach to the court ruling that overturned the part of a CFPB April 2020 Home Mortgage Disclosure Act (HMDA) rule that increased the threshold to report closed-end mortgage loans from 25 covered loans originated in each of the prior two years to 100 covered loans originated in each of the prior two years.… Continue Reading

The CFPB’s Office of Research recently issued a blog post regarding its analyses of the impacts of higher mortgage interest rates on borrowers and potential homebuyers.  The analyses are based on first and second quarter Home Mortgage Disclosure Act (HMDA) data filed by the 55 mortgage lenders that are required, based on their high volume of mortgage lending, to collect and submit HMDA data on a quarterly basis. … Continue Reading

In April 2020, the CFPB issued a final HMDA rule increasing the Home Mortgage Disclosure Act (HMDA) reporting threshold for closed-end mortgage loans from 25 covered loans originated in each of the prior two years to 100 covered loans originated in each of the prior two years. The federal district court for the District of Columbia recently invalidated the change, although the court let stand the increase in the permanent threshold for reporting open-end lines of credit made by the April 2020 rule from 100 covered lines of credit in each of the two prior years to 200 covered lines of credit in each of the two prior years.… Continue Reading

The Federal Financial Institutions Examination Council (FFIEC) recently announced the public availability of Home Mortgage Disclosure Act data for 2021.  The CFPB also released a summary of the data.  The data include information on 23.8 million home loan applications, with 21.1 million being identified as closed-end loan applications.  A total of 15 million applications resulted in loan originations. … Continue Reading

Earlier this week, the CFPB issued a Request for Information (RFI) regarding an assessment of the significant amendments to the Home Mortgage Disclosure Act rules, known as Regulation C, adopted in October 2015 and subsequently revised in several additional rulemakings (the “HMDA Rule”).  Responses to the RFI will be due 60 days after it is published in the Federal Register.Continue Reading

The CFPB recently released a report entitled Data Point 2020: Mortgage Market Activity and Trends addressing 2020 Home Mortgage Disclosure Act (HMDA) data.

Among various highlights, the Report provides that 4,472 financial institutions reported at least one closed-end loan in 2020, which is down by 18.8 percent from 5,505 financial institutions that reported in 2019.… Continue Reading

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