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Congress enacted the Truth in Lending Act (TILA) in 1968 based on findings that the informed use of credit resulting from consumers’ awareness of the cost of credit would enhance economic stability and would strengthen competition among consumer credit providers. One of the purposes of TILA is to provide meaningful disclosure of credit terms to enable consumers to compare credit terms available in the marketplace more readily and avoid the uninformed use of credit. TILA

The Consumer Financial Protection Bureau (CFPB) recently announced a key initial step in implementing its Nonbank Supervision program — the publication of the Mortgage Origination Examination Procedures (MOEP). The procedures are a field guide for CFPB examiners looking at mortgage originators in both the bank and nonbank sectors of the industry. The procedures are significant for two reasons: A lightly regulated segment of the mortgage market – independent lenders, brokers, servicers, and others unaffiliated with

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