Numerous regulatory requirements have thresholds that change annually. Following is a review of several of the lending thresholds that have changed recently. CRA – Small Bank and Intermediate Small Bank – Effective January 1, 2105 each federal financial institution regulatory agency defines the term “small bank” to mean a bank that, as of December 31 of either of the prior two calendar years, had assets of less than $1.221 billion. The term “intermediate small bank” means a small […]
Category: Regulation C
2013 HMDA DATA NOW AVAILABLE
On September 22, 2014 the Federal Financial Institutions Examination Council (FFIEC) announced the availability of data on mortgage lending transactions at 7,190 U.S. financial institutions covered by the Home Mortgage Disclosure Act (HMDA). Covered institutions include banks, savings associations, credit unions, and mortgage companies. The HMDA data cover 2013 lending activity, and include applications, originations, purchases and sales of loans, denials, and other actions related to applications. The data also include disclosure statements for […]
HMDA PROPOSAL PUBLISHED
On July 24, 2104 the Consumer Financial Protection Bureau (CFPB) published proposed rules to implement changes to the Home Mortgage Disclosure Act (HMDA). Some of the proposed changes are mandated by the Dodd-Frank Act, others are part of a CFPB effort to modernize and streamline regulations. Comments on the 572-page proposal are due on or before October 22, 2014. Coverage There had been speculation that coverage would be expanded to all mortgage lenders that originated […]
WHAT IS MISMO?
The Mortgage Industry Standards Maintenance Organization, (MISMO) is a not-for-profit subsidiary of the Mortgage Bankers Association (MBA). It is a developer of technology standards for both residential and commercial property transactions. By promoting improved data consistency, MISMO aims to reduce costs and increase transparency while promoting confidence in mortgages as an asset class for investors. MISMO develops and maintains a comprehensive set of standards and data points for all stages of the mortgage loan life […]
WHERE’S HMDA HEADED? PART 5 – OPERATIONAL IMPROVEMENTS
The Consumer Financial Protection Bureau (CFPB) wants to improve the collection, reporting and sharing processes for Home Mortgage Disclosure Act (HMDA) data. This effort has the potential to reduce the burdens on lenders; but in its short history the CFPB has not earned a reputation for taking action solely in the interest of financial institutions. Collection and Reporting Approximately 70 percent of all loans eventually sold to a Government-Sponsored Enterprise use the Uniform Loan Delivery Dataset […]