When Congress enacted the Dodd-Frank Act in 2010, it directed the Consumer Financial Protection Bureau (CFPB) to improve Home Mortgage Disclosure Act (HMDA) reporting. Under the current HMDA collection rules, covered lenders have to report certain residential mortgage information such as the type of loan, the census tract where the property is located, and the race and ethnicity of the borrower. Improving the kinds of information collected will make it easier to identify new consumer protection […]
Tag: Dodd-Frank Act
WHERE’S HMDA HEADED? PART 3 – WHAT TYPES OF LOANS AND APPLICATIONS WILL BE REPORTED?
Currently Regulation C requires creditors to report information regarding loans and applications made for one of three purposes: Home purchase; Home improvement; or Refinancing. Reporting of home equity lines of credit (HELOCs) used for these purposes is generally optional. Under Regulation C’s existing transaction reporting regime, certain loans that are secured by residential real property need not be reported (e.g., home equity loans with no stated purpose, HELOCs, certain reverse mortgages). Yet home improvement loans […]
WHERE’S HMDA HEADED – PART 2 – WHICH INSTITUTIONS ARE SUBJECT TO HMDA?
As part of its revisions to HMDA the Consumer Financial Protection Bureau (CFPB) is considering whether there is an opportunity to level the playing field between bank and nonbank lenders. Today, banks that meet certain conditions must submit annual reports even if they make only a single loan. However, nonbank mortgage lenders generally are required to report only if they make 100 loans and meet other conditions. The CFPB is considering a rule intended to […]
WHERE’S HMDA HEADED – PART I – OVERVIEW
The Home Mortgage Disclosure Act (HMDA) was enacted by Congress more than 35 years ago to increase public scrutiny of access to credit and residential mortgage lending. HMDA data: Contains information about the vast majority of mortgage loans in this country; Shows whether lenders are serving the housing needs of their communities; Gives public officials information that helps them make decisions and policies; and Reveals lending patterns that could be discriminatory. The Consumer Financial Protection […]
SPECIAL RULES FOR SMALL CREDITORS – AFFILIATES
The volume of change to the Truth-in-Lending Act and Regulation Z during the past year has been overwhelming. But in the midst of all the change Congress and the Consumer Financial Protection Bureau made an effort to lighten the load, a bit, for small creditors. So what breaks are available? And, who qualifies as a small creditor? Since the definition focuses, in part, on affiliates we are also concerned with who is an affiliate? Breaks […]