Implementing revised HMDA rules is a monumental task by any measure. The first phase is to determine scope and coverage, collect the data, and submit it to the CFPB. The second phase involves analyzing the data and determining the story told by that data. The scope of institutions covered by the revised rules has changed. The types of loans that are HMDA-reportable under the revised rules has changed. The list of information that must be […]
Category: HMDA
CFPB STANDS IN WAY OF SOLUTION TO HMDA REPORTING PROBLEM
Collection of 2017 HMDA data begins in less than two months. The Consumer Financial Protection Bureau announced last summer in its 2017 Filing Instructions Guide (FIG) that beginning with the HMDA data collected in 2017, filers will submit their HMDA data to the Consumer Financial Protection Bureau (CFPB) using a web interface referred to as the HMDA Platform. The HMDA Platform has not been released. That puts the industry in the awkward position of collecting 2017 […]
REGULATION B AND THE NEW UNIFORM RESIDENTIAL LOAN APPLICATION
On September 23 the Consumer Financial Protection Bureau (CFPB) published an Official Approval concerning the new Uniform Residential Loan Application and the collection of expanded Home Mortgage Disclosure Act information about ethnicity and race in 2017. The official approval was issued on September 23, 2016. Entities may rely on the official approval beginning January 1, 2017. The official approval is issued separately from, and without amending, the official interpretations to Regulation B contained in Supplement […]
HMDA FIG PUBLISHED
The much anticipated Filing Instructions Guide (FIG) has been published by the Consumer Financial Protection Bureau (CFPB). Actually the CFPB has published two FIGs – one for data collected in 2017 and one for data collected in 2018 or later. The 2017 FIG is 47 pages in length. The 2018 Guide is 78 pages in length. Both are dated July 2016. The CFPB has also published a Technology Review and Frequently Asked Questions documents, […]
WORKS IN PROCESS
“For the rest of this year and the next, our rulemaking agenda at the Consumer Bureau will remain quite active.” Director Richard Cordray recently stated. So what can we expect to see from the CFPB? The agency is working on new or revised rules for: Overdraft fees, including the opt-in process for overdraft coverage of electronic transactions; Collection and publication of data on small business lending (The Dodd-Frank Act required final rules by July 21, […]