The CFPB recently released a File Format Verification Tool for 2018 Home Mortgage Disclosure Act (HMDA) data. As we reported, in October 2015, the CFPB adopted significant changes to the HMDA rules that significantly expanded the amount of information that must be collected and reported. Calendar year 2018 is the first year in which the expanded data must be collected.… Continue Reading
CFPB Addresses Partial HMDA Exemption for Certain Depository Lenders
By Richard J. Andreano, Jr. on
The Consumer Financial Protection Bureau (CFPB) recently issued a statement regarding the partial exemption from Home Mortgage Disclosure Act (HMDA) reporting requirements for certain lower mortgage volume depository institution lenders that was adopted in the Economic Growth, Regulatory Relief, and Consumer Protection Act (Act).
As we reported previously, the Act exempts depository institutions and credit unions from the new reporting categories added by Dodd-Frank and the HMDA rule adopted by the CFPB with regard to (1) closed-end loans, if the institution or credit union originated fewer than 500 such loans in each of the preceding two calendar years, and (2) home equity lines of credit (HELOCs), if the institution or credit union originated fewer than 500 HELOCs in each of the preceding two calendar years.… Continue Reading
S.2155 Does Not Facilitate Discriminatory Lending
By Richard J. Andreano, Jr. on
In a blog post entitled “How S.2155 (the Bank Lobbyist Act) Facilitates Discriminatory Lending” Professor Adam Levitin claimed that “This bill functionally exempts 85% of US banks and credit unions from fair lending laws in the mortgage market.” The claim was set forth in bold and italic text. If the intent was to draw attention to the claim, it worked. … Continue Reading
New HMDA Guide Issued by the FFIEC
By Richard J. Andreano, Jr. on
Posted in HMDA, Regulatory and Enforcement
The Federal Financial Institutions Examination Council (FFIEC) has just issued an updated version of The Guide to HMDA Reporting: Getting It Right!
The Guide reflects the extensive changes to the Home Mortgage Disclosure Act rules that were adopted in October 2015 and became effective January 1, 2018. Until now, the most recent version of the Guide was the April 2013 edition.… Continue Reading
CFPB launches new formatting tool for HMDA reporting
By Ballard CFS Group on
On February 1, the CFPB announced the launch of the 2018 HMDA LAR Formatting Tool (the “Tool”). The Tool will help financial institutions create an electronic file to submit HMDA data collected in 2018 and reported in 2019. The Tool is not needed if the financial institution uses vendor or loan origination software to format their HMDA data into a pipe delimited text file, so this Tool will be most useful to those with small volumes of covered loans and applications.… Continue Reading
CFPB launches new HMDA online tool, continues rate spread calculator
By Richard J. Andreano, Jr. on
The CFPB has launched a new online “Digital Check Tool” to be used by companies reporting HMDA data starting January 1, 2018.
More specifically, the new tool supports the Universal Loan Identifier (ULI) requirements of the revised HMDA rule. The CFPB states on its website that the new tool can be used for two functions. … Continue Reading
CFPB adjusts HMDA data collection, TILA mortgage escrow thresholds
By Barbara S. Mishkin on
In notices published in today’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. … Continue Reading
CFPB, other agencies announce good faith efforts approach to revised HMDA rule enforcement; CFPB to engage in HMDA rulemaking to reconsider rules
By Richard J. Andreano, Jr. on
The CFPB has announced that with regard to the collection in 2018 of the expanded data fields under the revised Home Mortgage Disclosure Act (HMDA) rules, the CFPB does not intend to require data resubmission unless data errors are material, and does not intend to assess penalties with respect to errors in the data collected in 2018.… Continue Reading
FRB hosts 2017 interagency fair lending panel
By Brian Slagle on
The FRB recently hosted a fair lending “hot topics” webinar in conjunction the DOJ, HUD, CFPB, FDIC, OCC, and NCUA. The seven agencies discussed fair lending developments, including the revised HMDA reporting requirements, compliance management for consumer loans, and various issues related to fair lending complaints, investigations, and enforcement.
HMDA and Revised Regulation C:
Eric Wang, Deputy Fair Lending Director of the CFPB’s Office of Fair Lending and Equal Opportunity, emphasized that the CFPB is currently updating its HMDA exam procedures and that the industry should be “on the lookout” for the revised “Getting it Right” guide.… Continue Reading
CFPB Launches Beta Version of HMDA Platform
By Richard J. Andreano, Jr. on
On Friday November 3, 2017 the Consumer Financial Protection Bureau (CFPB) announced the launch of the Internet-based platform that financial institutions will use to submit data under the Home Mortgage Disclosure Act (HMDA).
Each user will need to register online for login credentials and establish an account in order to access the platform.… Continue Reading