Many of you are in the throes of scrubbing your Home Mortgage Disclosure Act (HMDA) data. Following are a few thoughts that might help improve your HMDA reporting. Many HMDA-reporters misreport data in the “Action Taken” and “Gross Annual Income” fields of the Loan Application Register (LAR). Commons errors involve: Using the wrong Action Taken code when the loan application has been identified as “a preapproval request that did not transition to a loan application,” […]
Category: Lending Compliance
THE CFPB INHERITS REGULATION X
Congress enacted the Real Estate Settlement Procedures Act of 1974 (RESPA) based on findings that significant reforms in the real estate settlement process were needed to ensure that consumers are provided with greater and more timely information on the nature and costs of the residential real estate settlement process and are protected from unnecessarily high settlement charges caused by certain abusive practices that Congress found to have developed. In 1990, Congress amended RESPA by adding […]
THE CFPB INHERITS REGULATION V
The Fair Credit Reporting Act (FCRA), enacted in 1970, sets standards for the collection, communication, and use of information bearing on a consumer’s creditworthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living. Historically, rulemaking authority for the FCRA has been divided among the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), the Federal Trade Commission (FTC), the National Credit Union Administration (NCUA), the Office of the Comptroller […]
RESUBMITTING HMDA DATA
Right now HMDA reporting banks across the nation are checking, double-checking, scrubbing and reviewing their HMDA data. Some will find errors. Correcting errors before the data has been submitted to your regulator is a fairly easy task. But when examiners, auditors or others find errors in data previously submitted to regulators how do you correct those prior year errors? Assume your calendar year 2010 HMDA data was submitted on schedule by March 1, 2011. During […]
THE CFPB INHERITS REGULATIONS N and O
Congress enacted section 626 of the Omnibus Appropriations Act (Omnibus Appropriations Act) on March 11, 2009 and directed the Federal Trade Commission (FTC) to commence a rulemaking proceeding within 90 days of enactment with respect to mortgage loans. On May 22, 2009, the enactment of the Credit Card Accountability Responsibility and Disclosure Act clarified the FTC’s rulemaking authority under the Omnibus Appropriations Act to specify that the FTC’s rulemaking based on its authority pursuant to the Omnibus […]