Archive

PROPOSED HMDA CHANGES

On May 2, 2019 the Consumer Financial Protection Bureau (CFPB) published a Notice of Proposed Rulemaking (NPRM), an Advanced Notice of Proposed Rulemaking (ANPR) and other items related to changes to Regulation C, which is the implementing regulation for the Home Mortgage Disclosure Act.  Notice of Proposed Rulemaking For closed-end mortgage loans, the NPRM proposes two alternatives that would permanently increase the coverage threshold from 25 to either 50 or 100 closed-end mortgage loans. For […]

CFPB RELEASES MODIFIED LARS

On March 29, the CFPB announced that the HMDA Modified Loan Application Register (LAR) data have been published for approximately 5,400 financial institutions. This is the first year in which additional data reported by certain institutions under the 2015 HMDA rule are available. The Modified LARs contain loan level information for 2018 on individual HMDA filers, modified to protect privacy. A copy of the CFPB’s press release is available here. The 2018 HMDA Modified LARs are […]

2019 GUIDE TO HMDA REPORTING RELEASED

The Federal Financial Institutions Examination Council (FFIEC) has released the 2019 edition of the publication, A Guide to HMDA Reporting – Getting it Right (aka the HMDA bible). The 2019 version includes amendments made to HMDA by the Economic Growth, Regulatory Relief, and Consumer Protection Act and the 2018 HMDA interpretive and procedural rule issued by the Consumer Financial Protection Bureau. A copy of the Guide is available at:  https://www.ffiec.gov/hmda/pdf/2019guide.pdf.  

HAPPY NEW YEAR!

2018 was an interesting year for those of us in the compliance field. We completed implementation of HMDA and TRID revisions, and got a jump start on implementing the provisions of the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA). In last year’s New Years greeting I stated, “In my 42-year career I have seen the pendulum swing from one extreme to another several times. Since the mortgage crisis 10 years ago we have […]