The CFPB recently released a regulatory and reporting overview reference chart for Home Mortgage Disclosure Act (HMDA) data to be collected in 2021. The CFPB notes that the chart is intended to be used as a reference tool for data points required to be collected, recorded, and reported under the HMDA rules, set forth in Regulation C, as amended through April 16, 2020.… Continue Reading
CFPB Announces Release of HMDA Guides for 2021 Data
By Richard J. Andreano, Jr. on
On August 21, 2020, the CFPB announced the release of the Home Mortgage Disclosure Act (HMDA) Filing Instruction Guide (FIG) for data that must be collected in 2021 and reported in 2022. The CFPB also announced the release of the Supplemental Guide for Quarterly Filers that also applies to 2021 data.… Continue Reading
CFPB Updates HMDA FAQs
By Richard J. Andreano, Jr. on
The CFPB recently updated its Home Mortgage Disclosure Act (HMDA) FAQs to add two items regarding multiple data points.
In one FAQ, the CFPB confirms that a lender must report the credit score, debt-to-income (DTI) ratio and combined loan-to-value (CLTV) ratio if they were a factor relied on in making a credit decision, even if the data was not the dispositive factor.… Continue Reading
FFIEC Announces Release of 2019 HMDA Data
By Richard J. Andreano, Jr. on
On June 24, 2020, the Federal Financial Institutions Examination Council (FFIEC) announced the release of the 2019 Home Mortgage Disclosure Act (HMDA) data. This is early. In recent years the data were released in August or September, although the 2017 data were released in May. 2019 is the second year for which institutions were required to collect and report data under the expanded information requirements adopted by the CFPB in the October 2015 HMDA rule amendments.… Continue Reading
CFPB Updates HMDA Small Entity Compliance Guide
By Richard J. Andreano, Jr. on
As previously reported, in April 2020 the CFPB released a final rule to increase the threshold to report closed-end mortgage loans under the Home Mortgage Disclosure Act (HMDA) from 25 to 100 originated loans in each of the prior two years, and to increase the permanent threshold to report dwelling-secured open-end lines of credit under HMDA from 100 to 200 originated lines in each of the prior two years.… Continue Reading
CFPB Raises HMDA Reporting Thresholds
By Richard J. Andreano, Jr. on
The CFPB recently issued a final Home Mortgage Disclosure Act (HMDA) rule to increase the threshold to report closed-end mortgage loans from 25 to 100 originated loans in each of the prior two years, and to increase the permanent threshold to report dwelling-secured open-end lines of credit from 100 to 200 originated lines in each of the prior two years.… Continue Reading
CFPB Updates HMDA FAQs
By Richard J. Andreano, Jr. on
The CFPB recently updated its Home Mortgage Disclosure Act (HMDA) FAQs, regarding the reporting of race, ethnicity and sex for applications taken by mail, internet or telephone.
The CFPB addresses the following question:
If a natural person applicant submits a mail, internet, or telephone application under Regulation C but does not provide race, ethnicity, or sex information, what should the financial institution report regarding whether this information was collected on the basis of visual observation or surname?… Continue Reading
2020 HMDA Guide Issued
By Richard J. Andreano, Jr. on
The Federal Financial Institutions Examination Council (FFIEC) recently issued the 2020 edition of the Guide to HMDA Reporting: Getting It Right! (2020 Guide).
As previously reported, in October 2019 the CFPB issued a Home Mortgage Disclosure Act (HMDA) final rule that:
- Continues until January 1, 2022 the temporary volume threshold that triggers reporting of open-end, dwelling-secured lines of credit of at least 500 originated lines of credit in each of the prior two calendar years.
CFPB Updates HMDA Guide
By Richard J. Andreano, Jr. on
As previously reported, in October 2019 the CFPB issued a final rule under the Home Mortgage Disclosure Act (HMDA) to:
- Continue until January 1, 2022 the temporary volume threshold that triggers reporting of open-end, dwelling-secured lines of credit of at least 500 originated lines of credit in each of the prior two calendar years.
CFPB Issues Final HMDA Rule
By Richard J. Andreano, Jr. on
The CFPB recently issued in final form two elements of a May 2019 Home Mortgage Disclosure Act (HMDA) proposed rule.
As previously reported, the May 2019 proposal would:
- Increase the volume threshold that triggers reporting of closed-end mortgage loans from at least 25 originated loans in each of the prior two calendar years to at least 50 originated loans in each of the prior two calendar years.