The CFPB recently posted the Reportable HMDA Data: A Regulatory and Reporting Overview Reference Chart for HMDA Data Collected in 2022, a 38-page reference chart covering each of the data points required to be collected, recorded, and reported under Regulation C. The chart is a reference tool for data points required to be collected, recorded, and reported under Regulation C. Relevant regulation and commentary sections are provided for ease of reference. The chart also incorporates the […]
Category: CFPB
CONSIDERATION OF RELIGION IN A BUSINESS LOAN APPLICATION
On December 9, 2021, the CFPB issued a Supervisory Highlights report, which shines a light on legal violations identified by the CFPB’s examinations in the first half of 2021. A surprising item on the list was that CFPB examiners found that lenders improperly considered small business applicants’ religion in their credit decisions. For religious institutions applying for small business loans, some lenders improperly utilized a questionnaire that contained explicit inquiries about an applicant’s religion. Following […]
CFPB ATTACKS BANK FEES
In a recent blog post and in recent training we pointed out the financial institution regulatory agencies attack on overdraft fees. Now the attack is being broadened. On January 26, 2022, the Consumer Financial Protection Bureau (CFPB) issued a request for public comment on the topic of Fees Imposed by Providers of Consumer Financial Products or Services. Comments will be accepted until March 31, 2022. The request is a chance for the public to share […]
FINAL 2022 LENDING THRESHOLDS PUBLISHED
On December 23, 2022, the Consumer Financial Protection Bureau (CFPB) published the final 2022 lending thresholds. The CFPB published a final rule amending Regulation C to reflect the asset-size exemption threshold for banks, savings associations, and credit unions based on the annual percentage change in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W). Based on the 4.7 percent increase in the average of the CPI-W for the 12-month […]
REVISED HMDA EXAMINATION PROCEDURES
On December 17, 2021, the Office of the Comptroller of the Currency (OCC) issued OCC Bulletin 2021-63, which contains interagency Home Mortgage Disclosure Act, (HMDA) examination procedures. The revised procedures address changes to: The effective dates for banks that meet or exceed either the closed-end mortgage loans or the open-end lines of credit loan-volume threshold in each of the two preceding calendar years: Effective July 1, 2020, a bank, savings association, or credit union that […]