Archive

HMDA CLARIFICATION

On April 13, 2017 the Consumer Financial Protection Bureau published 150-page proposed update to Regulation C. The changes should help financial institutions comply with the 2015 HMDA Final Rule by clarifying the information they are required to collect and report about their mortgage lending. The proposal contains a number of clarifications, technical corrections, and minor changes to the HMDA regulation. These include clarifying certain key terms, such as “temporary financing” and “automated underwriting system.” The […]

HMDA – HUGE ERRORS, HUGE PENALTIES

Recently the Consumer Financial Protection Bureau (CFPB) ordered Nationstar Mortgage LLC, of Coppell, Texas, to pay a $1.75 million civil penalty for violating the Home Mortgage Disclosure Act (HMDA) by consistently failing to report accurate data about mortgage transactions for 2012 through 2014, and to take the necessary steps to improve its compliance management and prevent future violations. This is the largest HMDA penalty ever imposed by the CFPB. According to 2014 data, Nationstar was […]

PROPOSED CHANGES TO REGULATION B

The CFPB released proposed changes to Regulation B on Friday, March 24th.  The proposal, a mere 56 pages, is designed to permit creditors additional flexibility in complying with Regulation B, in order to facilitate compliance with Regulation C – HMDA.  This proposal was not unexpected. In October 2015, the CFPB issued final rules to implement changes to Regulation C that allow an applicant to self-identify using disaggregated ethnic and racial categories.  These rules are generally […]

KICKBACK SCHEME – PROSPECT MORTGAGE AND OTHERS

On January 21, 2017 the Consumer Financial Protection Bureau (CFPB) took action against Prospect Mortgage, LLC, a major mortgage lender, for paying illegal kickbacks for mortgage business referrals. The CFPB also took action against two real estate brokers and a mortgage servicer that took illegal kickbacks from Prospect. Under the terms of the action, Prospect will pay a $3.5 million civil penalty for its illegal conduct, and the real estate brokers and servicer will pay […]

ANOTHER PIECE OF THE HMDA PUZZLE RELEASED

I am an avid fan of the show Blindspot!  For those of you who are not familiar, it revolves around a mysteriously tattooed woman found in a bag in Times Square who has lost her memory and does not know her identity.  The FBI discovers that her tattoos contain clues to crimes they have to solve.  One tattoo is revealed and investigated per episode and the crime is solved in the one-hour episode.  I sometimes […]