WHERE’S HMDA HEADED? PART 5 – OPERATIONAL IMPROVEMENTS
Category: CFPB, Dodd-Frank Act, FFIEC, HMDA, Lending Compliance, Regulation C
The Consumer Financial Protection Bureau (CFPB) wants to improve the collection, reporting and sharing processes for Home Mortgage Disclosure Act (HMDA) data. This effort has the potential to reduce the burdens on lenders; but in its short history the CFPB has not earned a reputation for taking action solely in the interest of financial institutions. Collection and Reporting Approximately 70 percent of all loans eventually sold to a Government-Sponsored Enterprise use the Uniform Loan Delivery Dataset
HUGE UDAAP PENALTY
Category: CFPB, Lending Compliance, UDAAP
The CFPB announced that Bank of America has agreed to pay $772 million in refunds and penalties for deceptive credit card practices. Please don’t stop reading just because the case involves a big bank and credit card issues. The deceptive practices in this case involved debt cancellation and identity theft monitoring products which may be a concern for banks of any size and for many products other than credit cards. A simple rule for deciding
WHERE’S HMDA HEADED – PART 4 EXPANDED INFORMATION FOR EACH LOAN OR APPLICATION
Category: CFPB, Dodd-Frank Act, HMDA, Lending Compliance, Regulation C
When Congress enacted the Dodd-Frank Act in 2010, it directed the Consumer Financial Protection Bureau (CFPB) to improve Home Mortgage Disclosure Act (HMDA) reporting. Under the current HMDA collection rules, covered lenders have to report certain residential mortgage information such as the type of loan, the census tract where the property is located, and the race and ethnicity of the borrower. Improving the kinds of information collected will make it easier to identify new consumer protection
WHERE’S HMDA HEADED? PART 3 – WHAT TYPES OF LOANS AND APPLICATIONS WILL BE REPORTED?
Category: CFPB, Dodd-Frank Act, HMDA, Lending Compliance, Regulation C
Currently Regulation C requires creditors to report information regarding loans and applications made for one of three purposes: Home purchase; Home improvement; or Refinancing. Reporting of home equity lines of credit (HELOCs) used for these purposes is generally optional. Under Regulation C’s existing transaction reporting regime, certain loans that are secured by residential real property need not be reported (e.g., home equity loans with no stated purpose, HELOCs, certain reverse mortgages). Yet home improvement loans
WHERE’S HMDA HEADED – PART 2 – WHICH INSTITUTIONS ARE SUBJECT TO HMDA?
Category: CFPB, Dodd-Frank Act, HMDA, Lending Compliance, Regulation C
As part of its revisions to HMDA the Consumer Financial Protection Bureau (CFPB) is considering whether there is an opportunity to level the playing field between bank and nonbank lenders. Today, banks that meet certain conditions must submit annual reports even if they make only a single loan. However, nonbank mortgage lenders generally are required to report only if they make 100 loans and meet other conditions. The CFPB is considering a rule intended to
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