Archive

REGULATION B FINAL RULE – MONITORING INFORMATION

On September 20, 2017 the Consumer Financial Protection Bureau (CFPB) published final revisions to Regulation B, which implements the Equal Credit Opportunity Act (ECOA), to provide additional flexibility for mortgage lenders in the collection of consumer ethnicity and race information. Regulation B includes restrictions regarding lenders’ ability to ask consumers about their race, color, religion, national origin or sex, except in certain circumstances. These circumstances include required collection of the information for some mortgage applications […]

CFPB Takes Steps Toward Small Business Lending Data Collection Rules

The Consumer Financial Protection Bureau (CFPB) has begun to take steps toward implementing rules related to small business lending data collection. On May 10, 2017, the CFPB issued a Request for Information (RFI) regarding the small business lending market. This RFI coincides with a field hearing, on the same topic, set to take place later today in Los Angeles, California. Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) amended […]

GEOCODING TOOLS ABOUND!

If your financial institution is a HMDA reportable financial institution, then you are intimately familiar with geocoding and the headaches that the process causes when it comes to completing your HMDA LAR.  The property location data fields (state, county, MSA, census tract codes, etc.) account for many of the errors that your regulatory agency identifies when completing data integrity on your LAR.  Well, CFPB to the rescue (insert sigh)! As we reported in a recent […]

PROPOSED CHANGES TO REGULATIONS B AND C

The CFPB has been busy with proposed changes in recent weeks.  Two proposed changes released by the CFPB will impact most financial institutions to some degree.  The CFPB released proposed changes to Regulation B on March 24, 2017.  The proposal is designed to permit creditors additional flexibility in complying with Regulation B – ECOA, in order to facilitate compliance with Regulation C – HMDA.  This proposal was not unexpected.  In addition, the CFPB released changes […]

PROPOSED CHANGES TO REGULATION B

The CFPB released proposed changes to Regulation B on Friday, March 24th.  The proposal, a mere 56 pages, is designed to permit creditors additional flexibility in complying with Regulation B, in order to facilitate compliance with Regulation C – HMDA.  This proposal was not unexpected. In October 2015, the CFPB issued final rules to implement changes to Regulation C that allow an applicant to self-identify using disaggregated ethnic and racial categories.  These rules are generally […]