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
Mortgages
CFPB Announces Availability of HMDA Filing Platform for 2020 Data
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…
FHFA Seeks Input on Appraisal Policies for Home Mortgage Loans
The Federal Housing Finance Agency (FHFA) recently issued a request for information (RFI) seeking input on appraisal-related policies, practices and processes in connection with home mortgage loans. Comments will be due 60 days after the RFI is published in the Federal Register.
FHFA is seeking input on four main topics:
- Aspects of Fannie
…
CFPB issues mortgage servicing consent order
On December 18, 2020, the CFPB announced a consent order with Seterus, Inc. (Seterus), and its successor-in-interest, Kyanite Services, Inc. (Kyanite), based on findings of mortgage servicing violations.
The consent order alleges the following violations by Seterus while it was in operation:
- Unfair acts or practices for failing to accurately review, process, track, and communicate
…
CFPB Adjusts HMDA and TILA Asset Exemption Thresholds
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…
CFPB Finalizes Ability to Repay/Qualified Mortgage Rules
The CFPB recently issued a final rule amending Regulation Z ability to repay rule/qualified mortgage (QM) requirements to replace the strict 43% debt-to-income (DTI) ratio basis for the general QM with an annual percentage rate (APR) limit, while still requiring the consideration of the DTI ratio or residual income. The CFPB also issued a final…
CFPB Updates HMDA Guide for 2021 Data
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…
CFPB Announces No Change in HPML Appraisal Exemption Threshold
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…
HUD Proposes Rule to Permit Use of Private Flood Insurance Policies with FHA Loans
The U.S. Department of Housing Urban Development (HUD) announced a proposed rule to permit the use of private flood insurance policies with FHA mortgage loans. As previously reported, in February 2019 federal regulators issued a joint final rule (the “Joint Final Rule”) to implement provisions of the Biggert-Waters Flood Insurance Reform Act of 2012…
The CFPB’s final collections rule: mortgage servicing provisions and impacts
On November 13, 2020, from 12:00 p.m. to 1:00 p.m. ET, we will present a webinar on the CFPB’s final collection rule. Click here for more information and to register.
The CFPB’s debt collection final rule will significantly impact the operations of mortgage servicers. Not surprisingly, the CFPB declined to generally exempt mortgage servicers from…