Archive

HMDA – HUGE ERRORS, HUGE PENALTIES

Recently the Consumer Financial Protection Bureau (CFPB) ordered Nationstar Mortgage LLC, of Coppell, Texas, to pay a $1.75 million civil penalty for violating the Home Mortgage Disclosure Act (HMDA) by consistently failing to report accurate data about mortgage transactions for 2012 through 2014, and to take the necessary steps to improve its compliance management and prevent future violations. This is the largest HMDA penalty ever imposed by the CFPB. According to 2014 data, Nationstar was […]

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 […]

ANOTHER PIECE OF THE HMDA PUZZLE RELEASED

I am an avid fan of the show Blindspot!  For those of you who are not familiar, it revolves around a mysteriously tattooed woman found in a bag in Times Square who has lost her memory and does not know her identity.  The FBI discovers that her tattoos contain clues to crimes they have to solve.  One tattoo is revealed and investigated per episode and the crime is solved in the one-hour episode.  I sometimes […]

PHASE II OF THE HMDA REVISIONS

Implementing revised HMDA rules is a monumental task by any measure. The first phase is to determine scope and coverage, collect the data, and submit it to the CFPB. The second phase involves analyzing the data and determining the story told by that data. The scope of institutions covered by the revised rules has changed. The types of loans that are HMDA-reportable under the revised rules has changed. The list of information that must be […]

CFPB STANDS IN WAY OF SOLUTION TO HMDA REPORTING PROBLEM

Collection of 2017 HMDA data begins in less than two months. The Consumer Financial Protection Bureau announced last summer in its 2017 Filing Instructions Guide (FIG) that beginning with the HMDA data collected in 2017, filers will submit their HMDA data to the Consumer Financial Protection Bureau (CFPB) using a web interface referred to as the HMDA Platform. The HMDA Platform has not been released. That puts the industry in the awkward position of collecting 2017 […]