Archive

OTTING MISSTATEMENT

Last week Comptroller of the Currency Joseph M. Otting issued a statement after meeting with Mick Mulvaney, Acting Director of the Consumer Financial Protection Bureau. According to the news release (NR 2018-14) from the Office of the Comptroller of the Currency (OCC)  Comptroller Otting stated “Acting Director Mulvaney has helped reduce the burden on the banking system by delaying implementation of his agency’s Home Mortgage Disclosure Act rule, committing to reconsider its payday lending rule, and […]

LATEST REVISIONS TO HMDA TOOLS

On February 2, 2018 the Consumer Financial Protection Bureau (CFPB) updated its Resources for HMDA Filers page by adding a 2018 LAR Formatting Tool, and making minor updates to the 2018 Filing Instructions. The 2018 LAR Formatting Tool is designed to assist financial institutions create an electronic file that can be submitted to the HMDA platform. It can be used to collect 2018 data that is to be reported in 2019. The CFPB also updated […]

CFPB LAUNCHES ADDITIONAL HMDA TOOLS

On December 27, 2017 the Consumer Financial Protection Bureau(CFPB) launched its HMDA Check Digit Tool and Rate Spread Calculator. These tools, or similar tools, are needed to assure compliance with new HMDA data collection rules that are effective on January 1.2018. HMDA Check Digit Tool – The Check Digit Tool: Generates a two character check digit when you enter a Legal Entity Identifier (LEI) and loan or application ID; and Validates that a check digit […]

FINAL 2018 LENDING THRESHOLDS

Each year more than a half dozen lending thresholds are published by the federal regulators from mid-summer to the last days of the year.. The thresholds determine coverage for various requirements in the Home Mortgage Disclosure Act, the Truth in Lending Act and the Community Reinvestment Act. On December 27, 2017 the Consumer Financial Protection Bureau (CFPB) published the final lending thresholds for 2017. The HMDA asset-size exemption threshold was increased from $44 million to […]

CFPB ANNOUNCES HMDA FORBEARANCE

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 […]