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 that the CFPB inherited from other regulatory agencies on July 21, 2011, including, among others, Regulation Z (Truth in Lending) and Regulation X (RESPA). The inherited regulations are published in Chapter X of Title 12 of the Code of Federal Regulations. Following is the schedule of […]
Category: HMDA
CFPB – THE INHERITED REGULATIONS
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 […]
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 […]