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With continued problems in the mortgage markets, some HMDA-reporting institutions may be required to repurchase loans from an investor because of defaults or may have the opportunity to acquire loans in bulk from another institution. When a loan is repurchased by the originator within the same calendar year as originated, the originator should not report it as sold, and the purchaser (that subsequently puts it back to the originator) should not report it as purchased. […]

Many of you are in the throes of scrubbing your Home Mortgage Disclosure Act (HMDA) data. Following are a few thoughts that might help improve your HMDA reporting. Many HMDA-reporters misreport data in the “Action Taken” and “Gross Annual Income” fields of the Loan Application Register (LAR). Commons errors involve: Using the wrong Action Taken code when the loan application has been identified as “a preapproval request that did not transition to a loan application,” […]

Today the Consumer Financial Protection Bureau (CFPB) has established its Office of Minority and Women Inclusion (OMWI), under the guidance of the CFPB’s OMWI working group. An overarching goal for this working group is to ensure the integration of the OMWI mission throughout the Bureau. Among other requirements, OMWI is charged, by statute, with developing standards for: Equal employment opportunity, workforce diversity, and inclusion at all levels of the agency; Increased participation of minority-owned and […]

Congress enacted the Real Estate Settlement Procedures Act of 1974 (RESPA) based on findings that significant reforms in the real estate settlement process were needed to ensure that consumers are provided with greater and more timely information on the nature and costs of the residential real estate settlement process and are protected from unnecessarily high settlement charges caused by certain abusive practices that Congress found to have developed. In 1990, Congress amended RESPA by adding […]

The Fair Credit Reporting Act (FCRA), enacted in 1970, sets standards for the collection, communication, and use of information bearing on a consumer’s creditworthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living. Historically, rulemaking authority for the FCRA has been divided among the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), the Federal Trade Commission (FTC), the National Credit Union Administration (NCUA), the Office of the Comptroller […]