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2012 HMDA DATA

Earlier this week the Federal Financial Institutions Examination Council (FFIEC) announced the availability of data on mortgage lending transactions at 7,400 U.S. financial institutions covered by the Home Mortgage Disclosure Act (HMDA). The HMDA data covers 2012 lending activity — applications, originations, purchases and sales of loans, denials, and other actions related to applications. The data include disclosure statements for each financial institution, aggregate data for each metropolitan statistical area (MSA), nationwide summary statistics regarding […]

MORE FINAL REVISED RULES – REGULATIONS B, X, AND Z

On September 13 the Consumer Financial Protection Bureau published it latest revisions to final rules that were published last January. The 274-page final rule: Revises error resolution procedures and information requests (§§ 1024.35 and 1024.36), and loss mitigation (§ 1024.41). With respect to loss mitigation, two of the revisions concern the requirement in § 1024.41(b)(2)(i) that a servicer review a borrower’s loss mitigation application within five days and provide a notice to the borrower acknowledging […]

REGULATION E CIVIL MONETARY PENALTIES

Case 1 – In late July an Indiana bank was assessed a $70,000 penalty for engaging in unfair and deceptive acts or practices by the imposition of requirements on consumers in the resolution of electronic transfer errors which were more onerous than those set forth in Regulation E, thereby effectively delaying, denying or discouraging error resolution claims. Case 2 – In mid-July a bank located in Kentucky was assessed a $100,000 penalty for engaging in unfair […]