Section 1003.4(a)(13) of Regulation C requires that the Loan Application Register indicate, among other items, whether the loan is subject to the Home Ownership and Equity Protection Act of 1994 (HOEPA), as implemented in Regulation Z (12 CFR 1026.32). Under current rules a loan secured by a consumer’s principal dwelling is subject to HOEPA if the loan has a high rate or high fees. Currently a loan has high fees if the total points and […]
Category: HMDA
2012 HMDA DATA
Earlier this week the Federal Financial Institutions Examination Council (FFIEC) announced the availability of data on mortgage lending transactions at 7,400 U.S. financial institutions covered by the Home Mortgage Disclosure Act (HMDA). The HMDA data covers 2012 lending activity — applications, originations, purchases and sales of loans, denials, and other actions related to applications. The data include disclosure statements for each financial institution, aggregate data for each metropolitan statistical area (MSA), nationwide summary statistics regarding […]
MOST RECENT CFPB SEMI-ANNUAL RULEMAKING AGENDA
Recently the Consumer Financial Protection Bureau (CFPB) published its most recent semiannual rulemaking agenda. There were no big surprises in the agenda. This article reviews three issues of concern. Integrated Disclosures and Finance Charge Rules – The biggest rules yet to be finalized are the new integrated disclosures. The disclosures include the loan estimate (that combines the early TIL disclosure and the good faith estimate) and the closing disclosure (that combines the final TIL disclosures […]
REVISED HMDA GUIDE
On April 18th the Federal Financial Institutions Examination Council (FFIEC) published an updated version of A Guide to HMDA Reporting: Getting It Right. This is the first time the Guide has been updated since 2010. The 2013 edition reflects the transfer of authority over Regulation C from the Federal Reserve Board to the Consumer Financial Protection Bureau. Appendix D, comment 1003.2 is updated with the asset-size threshold exemption applicable to collection of 2013 data. There […]
HMDA MACRO QUALITY EDITS
It’s that time of year when HMDA LARs are being scrubbed, double-checked and submitted to regulators. Once you submit the data the agencies begin their quality checks, which often result in Macro and Micro Quality Edits that need your attention. Below are agency-provided answers to some of the most common questions about macro quality edits, reasons for providing detailed explana¬tions on the Macro Quality Edit Report, and examples of acceptable macro edit responses. What is […]