During October 2015 the Consumer Financial Protection Bureau (CFPB) published final rules to amend Regulation C. The rules are effective, for the most part, on January 1, 2018. On April 13, 2017 the CFPB published substantially proposed revisions to the final rules. Again on July 14, 2017 the CFPB published additional changes to the final rules. Today, with the clock racing to the January 1st mandatory compliance date the CFPB published final rules (225 pages) […]
Category: Regulation C
HMDA – PROPOSED HELOC CHANGE
On July 14, 2017 the Consumer Financial Protection Bureau (CFPB) proposed amendments to Regulation C that would, for a period of two years, increase the threshold for collecting and reporting data with respect to open-end lines of credit so that financial institutions originating fewer than 500 open-end lines of credit in either of the preceding two years would not be required to begin collecting such data until January 1, 2020. Through outreach, the CFPB has […]
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 […]
HMDA CLARIFICATION
On April 13, 2017 the Consumer Financial Protection Bureau published 150-page proposed update to Regulation C. The changes should help financial institutions comply with the 2015 HMDA Final Rule by clarifying the information they are required to collect and report about their mortgage lending. The proposal contains a number of clarifications, technical corrections, and minor changes to the HMDA regulation. These include clarifying certain key terms, such as “temporary financing” and “automated underwriting system.” The […]