On December 21, 2017 the Consumer Financial Protection Bureau (CFPB) issued a public statement announcing that the CFPB: Does not intend to require data resubmission unless data errors are material or assess penalties with respect to errors for data collected in 2018 and reported in 2019 under the Home Mortgage Disclosure Act (HMDA). Intends to open a rulemaking to reconsider various aspects of the CFPB’s 2015 HMDA rule, such as the institutional and transactional coverage […]
Month: December 2017
2018 CRA THRESHOLDS PUBLISHED
On December 21, 2017 the Federal Deposit Insurance Corporation, Federal Reserve Board of Governors, and the Office of the Comptroller of the Currency, together referred to as the Agencies, published the annual adjustment to the asset-size thresholds used to define small bank, small savings association, intermediate small bank, and intermediate small savings association under the Community Reinvestment Act (CRA) regulations. Annual adjustments to these asset-size thresholds are based on the change in the average of […]
HMDA PLATFORM TESTING PERIOD APPROACHING FINALITY
On November 3, 2017, the CFPB released the much anticipated HMDA Platform. The platform is the web portal that HMDA covered financial institutions must utilize to submit HMDA data beginning with its 2017 HMDA data. The platform has been available for testing since November 3rd; however, the CFPB sent out a reminder today regarding the official closing date of the platform. The beta testing period will officially close on December 31, 2017 to allow the […]
DISCOUNT POINTS
On November 28, the Federal Reserve Board (FRB) issued a consent order against Peoples Bank (Peoples), Lawrence, Kansas, for deceptive residential mortgage origination practices in violation of section 5 of the Federal Trade Commission Act. Apparently Peoples told certain borrowers that they were paying an additional amount for discount points that would lower the borrowers’ interest rate. In fact, many borrowers did not receive a reduced rate. The consent order requires Peoples to pay approximately […]
MLA GUIDANCE PUBLISHED
On December 14, 2017 the Department of Defense (DoD) published some much needed clarification on the Military Lending Act (MLA). Previous DoD interpretations, in the form of 19 Questions and Answers published during August 2016, provided less than sufficient answers to certain questions. The new guidance eliminates much of the confusion on those issues by amending its guidance on three of the questions and by providing one additional question and answer. Question 2 is amended […]