On November 29th the Consumer Financial Protection Bureau (CFPB) published a notice and request for information about streamlining the inherited regulations. The “inherited regulations” include 14 existing consumer regulations, including, among others, Regulation Z (Truth in Lending) and Regulation X (RESPA), that the CFPB inherited from other regulatory agencies on July 21, 2011. The inherited regulations are published in Chapter X of Title 12 of the Code of Federal Regulations. On December 16, 2011 the […]
Category: HMDA
HMDA – WHAT IS A REFINANCE
Recently I got a question from a banker. “We have received conflicting information on what qualifies as a refinance. If we have the borrower sign a new note but keep the same note number, should we report the transaction as a refinance?” That’s a great question, but not so easy to answer. The failure to adequately define the term “refinance” is one of the Federal Reserve Board’s biggest screw-ups. We can only hope that when […]
YEAR-END HMDA NEWS
As part of the usual year-end flurry the Federal Reserve Board published its annual notice of the asset-size exemption threshold for depository institutions under Regulation C, which implements the Home Mortgage Disclosure Act (HMDA). The asset-size exemption for depository institutions will increase to $40 million based on the annual percentage change in the Consumer Price Index for Urban Wage Earners and Clerical Workers for the twelve-month period ending in November 2010. Depository institutions with assets […]